You Can Keep APD Records in Your Own System. That Right Is Written to Expire 1 July 2027.

There are two separate obligations here and almost every conversation about them runs the two together. One is where your service records live. The other is where your service authorizations come from. They have different answers, and mixing them up costs you either unnecessary work or a missed date.

This piece is mostly about the first one, because the answer people are working from is correct and has a clock on it that almost nobody has read.

What the law actually says about your records

Provider Advisory 2026-016 quotes Chapter 2025-199, Laws of Florida directly. As a condition of payment and before billing, providers "shall use agency data management systems to document service provision to clients or shall maintain such information in its own data management system and electronically transmit it to the agency in an industry standard electronic format designated by the agency."

The same passage goes further: the agency "may not require training on the use of agency data management systems" for providers who choose to keep their own system. So if you already run something that works, you are not being ordered to abandon it.

The part almost nobody knows: this flexibility has an expiry date

That choice is written into section 393.066(2), Florida Statutes — and the statute carries a note about its own future that is easy to miss, because it sits below the text rather than in it.

Section 45 of chapter 2026-233 provides that the text carried forward from chapter 2025-199 "expires July 1, 2027", and that the subsection then reverts to the version in existence on 30 June 2025. The statute prints what that reverted wording will say. From 1 July 2027, providers:

Read that carefully before you plan around it, in both directions. This is a scheduled expiry in an implementing bill tied to the 2026-2027 budget, and this flexibility has now been carried forward year to year — so the Legislature may well extend it again in 2027. It is not a settled fact that the door closes. What is a fact is that, as the law reads today, the door is scheduled to close on 1 July 2027, and nothing has to happen for that to occur. An extension is an action somebody has to take.

The practical read: keeping your records in your own system is a real and legal choice right now, and it is a reasonable one. Just do not build a five-year plan on a provision with a two-year clock on it without watching whether it gets renewed.

And Qlarant will look in either place

This is the part worth reading twice, because it is the one that decides whether a review costs you money. For quality assurance reviews in Fiscal Year 2026-2027, the advisory states:

• Qlarant "will review and accept documentation found in iConnect or in a provider's own data management system."
• Documentation supporting the standards in Qlarant's Provider Discovery Reviews is acceptable both inside and outside iConnect, and will be considered Met, with no recoupment during remediation.
• If the documentation is not found supporting those standards in either place, citations are issued and recoupment applies per the review tools.

Read the last bullet as the real rule. The location is genuinely flexible. The existence of the documentation is not.

The other date, the one that already passed

The 2026-2027 Implementing the General Appropriation Act, also quoted in the advisory, requires that waiver service providers obtain authorizations for services through the current client data management system beginning 1 July 2026. That system is iConnect.

So the advisory set a provisioning deadline: providers without iConnect access had to contact their APD Regional Provider Enrollment team to complete user provisioning prior to 1 October 2026. That date is the one that got all the attention, and it is the smaller of the two by a long way — it asked for a login, not a migration.

If you never got provisioned, the date passing did not make it optional. Authorizations come out of iConnect; without a login you cannot pull one, and without one you cannot bill. Providers can also designate Billing Agents within iConnect so those workers are notified automatically when an authorization is added or updated.

The trap inside the exemption

Here is where an operator who reads only the statute gets it backwards. Keeping your own system removes the obligation to be trained on agency systems. It does not remove the need for access.

APD's own External Provider Interface — the mechanism for sending documentation from your system into iConnect — states two prerequisites on its page: the provider must have current authorizations, and must have at least one logged in user. Authorizations come from iConnect. So the own-system route runs through iConnect access rather than around it.

EVV is a different question, with a different answer

If you deliver services in an EVV setting, the flexibility above does not reach you. The advisory is explicit: the 21st Century Cures Act requires the use of an EVV system, and under Florida's State-Mandated External Vendor model, use of iConnect's EVV system for service documentation is a federal requirement. That is a different regulator and a different obligation from everything else on this page.

What to do about it

• Check whether you have iConnect access at all. If nobody in your business has logged in, that is the whole task, and everything else on this page runs through it.
• If you do not, call your APD Regional Provider Enrollment team and ask to start user provisioning. The advisory names them as the route, and it takes a call rather than a form you can fill in at 11pm.
• Work out who actually needs a login. Access is per-person and the required courses differ by role, so this is worth deciding once rather than per new hire.
• Decide where your records live, deliberately. Either answer is allowed. Drifting into a half-and-half arrangement, where nobody can say which system holds the last quarterly summary, is the version that fails a review.
• If you chose your own system, put 1 July 2027 somewhere you will see it. Not to move early — the flexibility is real and legal right now, and it may well be carried forward again. But the version of this that hurts is finding out in June 2027 that it was not, with a migration to do and no time to do it in. Watch the 2027 session.

One more thing worth saying plainly: this advisory was published on 1 July 2026 and sits on APD's provider advisories page alongside nineteen others from this year. If you have not read that page since last year, that is not carelessness — it is a page most people only visit when somebody tells them to.

This article is general information for Florida APD group-home providers, not legal advice or a guarantee of compliance. Rules change and vary by region — always confirm the current requirement with the cited source and your APD regional office.