From Kendra Scalia's Electronic Visit Verification (EVV) is Here:  What you need to know and how to get inovolved:

"Geolocation tracking (GPS) is not a requirement of EVV.  This was clarified by CMS in their 2018 Frequently Asked Questions document. GPS is only one way to capture the location requirement.  Similarly, geofencing - which prohibits consumers and their employees from starting or ending a shift more than a certain distance from the consumer's home - is not required.  This technology actually harms consumers.  For a community that has historically been isolated from public spaces, and still continues to fight for access, geofencing forces disabled people to remain home bound against their will."