Short answer: no — Texas does not require electronic visit verification (EVV) for private-pay home care. The state's EVV mandate applies to services paid by Medicaid. If your agency bills clients and families directly, you are not legally required to run an EVV system. But the full picture is worth five minutes, because the rules tightened significantly in 2026, and the line between "exempt" and "required" is thinner than many agency owners realize.
Texas HHSC requires EVV for Medicaid-funded personal care services and, since the state's expansion under the federal 21st Century Cures Act, Medicaid-funded home health care services as well. Every visit paid by Medicaid must be electronically verified — who provided care, to whom, where, and exactly when — and matched to the claim.
Enforcement got stricter on January 30, 2026: HHSC ended its compliance grace periods, and claims for EVV-required services now simply do not get paid without a matching EVV visit record. For Medicaid providers, EVV stopped being a paperwork requirement and became a revenue requirement.
The details live on the HHSC EVV program page and the state's EVV Policy Handbook.
Two situations catch agencies off guard:
If you are strictly private-pay today but the Medicaid market is in your growth plans, it pays to build visit-verification habits before the state requires them.
Exempt does not mean it's not worth doing. The agencies choosing EVV without a mandate usually cite the same practical reasons:
If the state isn't dictating your system, you get to choose one that fits. Reasonable criteria for a small agency: caregivers should need nothing more than the phone in their pocket (no proprietary devices), GPS should be captured at check-in and check-out only — with caregiver consent — rather than continuous tracking, exceptions should generate alerts rather than reports someone has to remember to read, and the data should flow into payroll and invoicing instead of living in its own silo. Month-to-month pricing without per-visit fees keeps the economics sane at private-pay scale.
That's the checklist we built Visiting Systems against — EVV designed for Texas private-pay agencies rather than stripped-down Medicaid tooling.
Private-pay home care in Texas is exempt from the EVV mandate, and nothing announced so far suggests that's changing. Adopt EVV because verified visits make a private-pay agency more trustworthy, more efficient, and easier to grow — and if Medicaid is ever in your future, you'll already run the discipline the state will demand.
This article is general information, not legal advice. For your agency's specific obligations, consult HHSC guidance or a healthcare attorney.