Colorado's EVV Aggregator: How an Alternate EVV System Reports Visits to the State

Short answer: In Colorado you can run your visit verification on the state's own system, or on an alternate system you contract for yourself. HCPF, the state Medicaid agency, calls the alternate route a "Provider Choice" system. An alternate system reports through a state data aggregator run by Sandata. It sends your clients, your staff and your visits there, the aggregator checks the visits against Colorado's edit rules, and the EVV data goes on to the state's claims system, where it is matched to your claims. HCPF's technical documents ask the vendor to send visits at least daily. The agency stays responsible for the records either way, and a visit sitting in a vendor's system is not proof that the state received it. Some things are not published, and we list them at the end.

This article is written against the HCPF pages and documents named in the sources line, read on November 5, 2026. HCPF changes them, so check the current versions. It explains the reporting path and is not a guide to choosing a vendor. For that, read our comparison of Provider Choice and the state's system and our Colorado EVV requirements guide.

What "alternate EVV" means in Colorado

Providers search for "alternate EVV," and HCPF uses several names for the same thing. Its vendor page is titled "Electronic Visit Verification-Alternate Vendors" and refers to "Colorado's Alternative EVV program." Its solution information page says "Provider Choice EVV System." Its technical documents say "Third Party Alternate EVV System." They are one route.

The route exists because Colorado runs what it calls a hybrid model. HCPF's overview says "provider agencies may choose to use the State EVV Solution at no cost or utilize a Provider Choice EVV System by contracting with the vendor of their choice." It adds that "provider agencies will be responsible for costs associated with Provider Choice Solutions." The federal source is Section 12006 of the 21st Century Cures Act. It defines the system as one that electronically verifies visits by six elements: the type of service performed, the individual receiving it, the date, the location of service delivery, the individual providing it, and the time the service begins and ends. It covers personal care and home health services. HCPF says it "has expanded the scope of EVV in Colorado to other services similar in nature and service delivery," so check the service list in the EVV Program Manual for your codes.

What the aggregator is

HCPF's FAQ puts it this way: "The Data Aggregator is a behind-the-scenes tool used to transmit EVV data to the interChange from both the State EVV Solution and Provider Choice systems." The interChange is Colorado's Medicaid claims system. An alternate system is not a side door. Its records end up where the state system's records do.

The same FAQ answer says that agencies using an alternate system "will have read-only access to a web portal in the Data Aggregator to view visit data." Read-only matters: you do not fix a record in the aggregator portal. The manual says "Provider Choice EVV Systems submit new data to HCPF which updates existing records," so corrections are made in your vendor's system and sent again.

The Program Manual describes what happens next: records "transmitted to the State Solution by a Provider Choice system will be transmitted to HCPF's fiscal agent to match against claims during adjudication." EVV records do not bill. Claims are still submitted the usual way, and HCPF's overview says that claims missing or having incomplete EVV records "will show in the provider's Remittance Advice as EOB 3054 'EVV Record Required and Not Found' and the claim will deny."

How a visit travels from the caregiver to the state

HCPF links the technical specification and the Colorado addendum for alternate systems from its EVV resources page, and your vendor works from them. In outline, these are the points an owner or biller can use.

1. The vendor sends three kinds of records. Clients, employees (field staff) and visits. A visit for a client the aggregator does not know is rejected.
2. It goes by API, at least daily. Vendors are asked to send visits whatever their status, close to real time where they can.
3. A visit is complete only when it is clean. That means all required information is in and every exception on the visit has been cleared.
4. The aggregator acknowledges, then checks. It acknowledges receipt, then checks visits against Colorado's edit rules. Records that fail are rejected, and the fix is made in the alternate system and sent again.
5. Corrections travel with a reason. The vendor's system logs every change to a visit and sends the log with the record. Exceptions are cleared with the state's standard reason codes.
6. Location comes from the device. Where a visit is captured on a GPS-enabled device, location is required for both the start and the end.
7. Order is enforced. The alternate system numbers every record in sequence, and a record without a number is rejected.

What the agency has to do, state system against alternate system

Getting connected

HCPF's solution information page lays out the steps for an alternate system. Every EVV provider registers with Sandata through its self-registration portal, which is the process "to begin Provider Choice onboarding." Sandata then "will create an account to support testing" and send a testing guide and checklist to your vendor. Your vendor uploads test files and resubmits until errors are cleared. Sandata then asks you for a go-live date, "the date you choose to begin using your Provider Choice System," and sends credentials.

There is a shortcut. HCPF keeps a list of vendors that have connected to Sandata in Colorado. If you choose one, HCPF says that "precludes you from interface testing," and you can request production credentials. The page also says "HCPF does not endorse any vendor or recommend using a vendor from this list." A vendor that has not connected in Colorado needs a sponsoring Colorado provider before it can begin onboarding and testing; HCPF says it does not give testing access to vendors without one.

What stays on your desk

HCPF's August and September 2026 fact sheets are blunt about responsibility: "Providers are ultimately responsible for all aspects of EVV records submitted to HCPF, regardless of the technology they use," and "A visit recorded in a vendor system does not by itself confirm successful transmission to HCPF."

If the connection fails, HCPF's FAQ states the consequence: "no EVV information will be transmitted to HCPF." The September fact sheet tells agencies to assess the impact early, including whether dates of service are nearing timely filing, and says not to assume an open support ticket establishes timely filing. It also says the State EVV Solution "may be used as the active EVV submission pathway while a Provider Choice system transmission issue is being resolved." The August switching fact sheet says that temporary use "does not require a provider to permanently discontinue its Provider Choice system." The Program Manual, last updated October 26, 2026, says providers can use only one system at a time. HCPF has not reconciled those two statements on the pages we read, so ask Sandata how a temporary switch works for your agency before you need it.

A short routine follows:

• Ask your vendor how you can see that the aggregator accepted a given visit, and what a rejection looks like.
• Check the aggregator portal on a schedule, not only when a claim denies.
• Name who in your office works rejections.
• Write down your fallback: who calls Sandata, and how long you can carry delayed claims.

Where OutcomeGrid fits

OutcomeGrid's EVV page says the product "captures every visit with GPS mobile clock-in and clock-out, offers a telephony fallback, records all six Cures Act data elements, and transmits to the Sandata aggregator as a Provider Choice system." See OutcomeGrid EVV for the full page.

That is OutcomeGrid's own description of its product. HCPF does not publish an approval or certification for alternate systems, so we do not claim one here. Before you sign with any vendor, including us, ask where it stands with HCPF's list and Sandata's testing.

What we could not confirm

• Whether HCPF approves an alternate system. Its resources page labels the vendor list "List of Approved Alternative Vendors," while its vendor page says the Department "does NOT endorse any vendor." We found no criteria beyond interface testing.
• How long interface testing takes, or what a vendor or agency pays for it. HCPF publishes neither.
• Whether aggregator training is required or only recommended. HCPF's solution page says "free and recommended," while its manual and FAQ say it is required.
• How a temporary move to the State EVV Solution fits with the manual's one-system-at-a-time statement.
• The contents of Sandata's Error Handling Reference Guide, which we did not read.
• Anything from Medicaid.gov. The page was not reachable to us, so the federal requirement here comes from the statute text and HCPF's own page.

Sources: HCPF Electronic Visit Verification Overview, Solution Information, Alternate Vendors (page updated July 2, 2026) and Resources pages; HCPF EVV Program Manual (last updated 10/26/2026); HCPF EVV Frequently Asked Questions (page updated August 14, 2025); Colorado HCPF Third Party EVV Addendum v2.6 (September 23, 2026) and Alternate EVV Requirement Specification v7.1; HCPF fact sheets, Switching EVV Technologies (August 2026) and EVV Compliance When Using Provider Choice Systems (September 2026); 21st Century Cures Act, Section 12006 (H.R. 34, 114th Congress). This article is general information, not legal advice.