| Core architecture |
| Architecture model |
Split-data biometric model |
Biometric data (facial embeddings, match scores, attempt logs) stays internal on Encore's system. Only the 6 federally required EVV fields transmit to the state aggregator. Each visit carries a Biometric Success ID linking the internal biometric record to the aggregator visit record for audit. |
Aggregators are not equipped to ingest biometric templates. Biometrics are the internal proof layer — EVV fields are the compliance submission layer. |
Confirmed |
| Build approach |
Offline-first · React Native hybrid |
Single React Native codebase for Android tablet APK and caregiver phone app. Full functionality without internet. All data stored locally in AES-256 encrypted storage and synced when connectivity is restored. Timestamp recorded at scan, never at sync. |
Timestamp-at-scan is a hard EVV compliance requirement — aggregators require actual visit time, not upload time. |
Confirmed |
| Backend |
Node.js / NestJS + PostgreSQL |
NestJS structured module architecture appropriate for compliance-heavy requirements. PostgreSQL with AES-256 encryption at rest. Encryption keys stored separately from visit records. |
All API and aggregator transmissions TLS 1.2 minimum, TLS 1.3 preferred. |
Confirmed |
| Verification logic |
3-gate checkout logic |
At check-out, three gates run in sequence: (1) GPS matches patient's registered home address → auto-approve, (2) GPS matches an approved location from the care plan → auto-approve, (3) patient biometric confirms co-presence regardless of GPS → auto-approve. Any single gate passing clears the shift. All three failing triggers a flagged evidence package for coordinator review. |
Non-blocking by design. Caregiver is never prevented from proceeding — shift is logged and flagged. |
Confirmed |
| Sequence enforcement |
Aggregator ACK gates claim |
Claim generation is programmatically blocked until the state aggregator's acknowledgement is logged against the shift record. Cannot be manually bypassed. |
Prevents claims being submitted without verified EVV data — the root cause of most EVV-related denials. |
Confirmed |
| Biometric system |
| Biometric SDK |
FaceSDK — on-device |
FaceSDK processes biometric capture fully offline on the Android tablet and caregiver phone. Raw photos converted immediately to encrypted mathematical embeddings on-device. Raw images never stored — not on device, not on backend. Embeddings stored server-side, encrypted. |
On-device processing required for offline-first architecture. BAA to be executed with FaceSDK vendor before any live patient data is handled. |
Confirmed — FaceSDK |
| Caregiver enrollment |
3-angle face enrollment |
One-time facial enrollment on caregiver's personal phone prior to first shift — front, left, right angles. Raw images converted to encrypted embeddings immediately, originals deleted. Account remains Inactive until a coordinator manually activates the profile. |
Coordinator activation gate prevents unauthorised device access. Must comply with HIPAA and applicable Ohio/PA biometric privacy laws. |
Confirmed |
| Patient biometric |
Provisional photo → live upgrade |
Family uploads baseline photo at intake — immediately converted to embedding, original deleted. On the patient's first real shift, the kiosk captures a live scan that automatically upgrades the profile to high-fidelity. No coordinator action needed for the upgrade. |
HIPAA data minimisation: raw images are never stored long-term. Coordinator reviews initial photo quality before first shift. |
Confirmed |
| EVV verification method code |
BIO code — pending confirmation |
Sandata's Alt-EVV V5.0 schema includes a VerificationMethod field. If Ohio supports a BIO code, Encore EVV submits with it. If BIO is not yet supported, visits submit as MVV (GPS/Mobile Visit Verification) — satisfying the GPS compliance requirement — while the biometric match is retained as an internal audit flag only. |
Action required: confirm with Sandata / Ohio ODM which VerificationMethod codes are supported before build. Email: [email protected] |
Open — confirm Sandata |
| Hardware and device management |
| Tablet hardware |
Android kiosk tablet · one per caregiver |
Dedicated Android tablet per caregiver. Wintouch A10 or equivalent. MDM-locked to single-app kiosk mode. Caregiver carries the tablet to every visit — tablet never lives at the patient's home. 10,000mAh power bank standard issue. Spare tablet pool maintained at the office. See tablet procurement section for pricing and MOQ details. |
Front camera required for biometric scan. Caregiver-carries model confirmed. |
Confirmed |
| MDM platform |
ManageEngine (recommended) or Jamf |
MDM enforces Android single-app kiosk lock. Blocks home button, status bar, quick settings, and notifications. OTA updates pushed overnight. Zero-touch enrollment via Android Zero-Touch portal — tablets auto-configure on first Wi-Fi connection. MDM heartbeat feeds coordinator dashboard with live device status. Remote wipe, lock, and location tracking enabled. |
See MDM comparison below. ManageEngine recommended for initial Ohio fleet. Revisit at scale. |
Decision required |
| EVV aggregator integration |
| Ohio routing |
All patients → Sandata Ohio |
Ohio's sole EVV aggregator. All Ohio patients regardless of payer (FFS, Aetna, Buckeye, CareSource, Humana, Molina, United) route to Sandata. EVV data formatted to Sandata Ohio Alt-EVV technical spec and transmitted in near real-time. |
Ohio is the target go-live state. Single aggregator — simpler certification path. Contact ODM immediately to enter the certification queue. |
Confirmed |
| Pennsylvania FFS |
FFS + waivers → Sandata PA |
PA fee-for-service and waiver patients (ACT150, DDD) route to Sandata under PA DHS configuration. Same vendor as Ohio, separate state configuration and separate certification. |
PA is the second certification phase after Ohio is live and stable. |
Confirmed |
| Pennsylvania MCO |
MCO patients → HHAeXchange |
PA MCO-managed patients (AmeriHealth, UPMC, Highmark, Health Partners, PA Health & Wellness, United) route to HHAeXchange. HHAeXchange automatically forwards to Sandata for PA DHS reporting — no double-submission needed. |
Contact: [email protected] to initiate alternate vendor setup. |
Confirmed |
| Routing logic |
Payer-driven automatic routing |
The payer/plan field captured at patient intake permanently determines which aggregator receives every future shift for that patient. No manual routing decision per visit. Routing table: Ohio + any plan = Sandata Ohio. PA + FFS/waiver = Sandata PA. PA + MCO = HHAeXchange. |
Payer/plan is a required field at intake. Must be set before patient's first visit. |
Confirmed |
| 835 ERA mapping |
Remittance mapped to shift records |
When the 835 ERA returns from Medicaid/MCOs, Encore EVV maps payment status (Paid / Denied / Short-paid) and denial reason codes back to the original shift record. Denied claims surfaced in the dashboard with reason code and correction path. |
Eliminates blind billing disputes. Billing team resolves EVV-related denials directly from the dashboard. |
Confirmed |
| Billing platform |
AxisCare — billing only |
AxisCare retained as billing backend only — not the EVV capture system. Data flow: Encore EVV → Sandata/HHAeXchange → AxisCare billing/claims submission. |
Confirmation required from AxisCare that their billing module can accept externally verified EVV records before build scope is finalised. |
Pending AxisCare API confirmation |
| Consent, compliance and legal |
| Biometric consent |
Explicit consent at intake — required |
Patient intake must include explicit, timestamped digital acknowledgement for: facial scanning at each visit, facial embedding storage in Encore's encrypted system, and biometric data used solely for shift verification. Checkbox with timestamp is minimum. Stored as immutable ePHI, 6-year minimum retention. |
Legal requirement in many states. HIPAA best practice regardless. Consent renewed if legal guardian changes. |
Confirmed |
| GPS consent |
Ohio ODM mandatory — separate consent |
Ohio requires signed patient consent before GPS coordinates can be captured (ODM form 10375 equivalent). Without consent, location logged as "home" or "community" only — no coordinates captured or transmitted. Patient record flagged as GPS-consent-pending. Consent renewed annually. |
Pennsylvania also requires GPS consent. Covers location at check-in/out and caregiver GPS breadcrumb data. |
Confirmed |
| HIPAA NPP |
Notice of Privacy Practices — at intake |
Federal requirement. Intake form includes acknowledgement of Encore Care's HIPAA Notice of Privacy Practices before any ePHI is collected. Timestamped and stored as immutable ePHI, 6-year minimum retention. |
All three consent types (biometric, GPS, HIPAA NPP) captured in step 2 of the patient intake flow. |
Confirmed |
| Proxy / POA handling |
Coordinator review gate |
For patients lacking capacity, a legal guardian or POA completes all consent sections. Coordinator reviews and uploads POA document or guardianship order in the patient record, then manually activates the patient profile. Patient cannot have first visit scheduled until coordinator marks proxy documentation as reviewed and on file. |
Coordinator review gate closes the loophole of unverified proxies completing a web form. All proxy consents stored as immutable ePHI. |
Confirmed |
| Exception handling and fraud prevention |
| Scan failure |
3 attempts → flag and mandatory note |
Maximum 3 biometric scan attempts. After 3 failures: shift is logged and flagged. Caregiver must submit a mandatory, immutable free-text note before screen dismisses. Note becomes part of the coordinator evidence package. Caregiver is never blocked from proceeding — care is never interrupted. |
Shift continues as flagged. Surfaces in coordinator queue for review with full evidence package. |
Confirmed |
| Biometric exemption |
Coordinator-set patient exemption flag |
Coordinator can mark a patient profile as biometric-exempt (e.g. severe physical limitations). All future shifts for that patient skip the patient scan step and route to supervisor spot-check protocol. Exempt flag stored on patient profile, not the shift record. |
Exempt shifts reported separately from biometric-failed shifts in all compliance reports. |
Confirmed |
| Internal fraud prevention |
Coordinator cannot approve own shifts |
Hard API-level constraint prevents any coordinator from approving a flagged shift where they are also listed as the active caregiver. Enforced at API level — cannot be bypassed by frontend manipulation. |
Essential for internal fraud prevention and Medicaid audit integrity. |
Confirmed |
| Family anti-collusion |
Read-only family portal — API enforced |
Families can view verified shift histories and opt into arrival/departure notifications. Hard API limits prevent families from adding approved locations, editing care plans, or approving/rejecting shifts. |
Prevents coordination between caregivers and families to fabricate visits. |
Confirmed |
| HIPAA and security |
| Encryption |
AES-256 at rest · TLS 1.3 in transit |
AES-256 for tablet local storage, backend database, and biometric embeddings. Encryption keys stored separately from visit records. TLS 1.2 minimum, TLS 1.3 preferred for all transmissions. |
Every EVV transmission is a transfer of ePHI — encryption applies end-to-end. |
Confirmed |
| Access control |
MFA + RBAC + auto-logout |
Unique user IDs and MFA for all coordinator/admin access. RBAC enforced at API level. Auto-logout: 15 min dashboard, 30 min phone app, 60s kiosk tablet. |
Auto-logout timers required for devices handling ePHI in patient homes. |
Confirmed |
| Audit logging |
Immutable audit logs · 6-year retention |
Every read and write action involving ePHI generates an immutable audit log: user ID, action type, record ID, timestamp. Cannot be edited or deleted by anyone including admins. |
All coordinator decisions permanently appended to evidence packages as immutable entries. |
Confirmed |
| May 2026 HIPAA updates |
Asset register + 72hr incident response |
Living inventory of every asset touching ePHI — tablet serial numbers, MDM status, cloud servers, SDKs, APIs. Documented and tested 72-hour system restoration and breach notification plan. Annual pen testing infrastructure built in from day one. |
New mandates effective May 2026. Must be architected for compliance from the first sprint. |
Confirmed |
| HIPAA Risk Assessment |
Third-party external assessment |
Mandatory third-party HIPAA Risk Assessment must be completed before any live patient data is handled. Cannot be self-certified. Completed against the staging environment before Ohio go-live. |
Cost paid to external assessor firm ($5K–$15K). Budgeted separately from build cost — see costs table. |
Required pre go-live |
| SOC 2 Type II |
External audit — begin at staging |
Engage external audit firm when staging is live. 6–12 month observation window required before certification can be issued. The clock starts when controls are in place — not when the decision is made. |
Cost paid to external audit firm ($20K–$50K). Starting the observation period early is the only way to compress time to certification. |
Required — begin at staging |