District of Columbia - Adult Companion Services — Licensing, Medicaid Enrollment and Startup Requirements
Last reviewed: 2026-09-09
The District of Columbia Department of Health Care Finance (DHCF) does not fund a standalone Adult Companion service under its Elderly and Persons with Physical Disabilities (EPD) Waiver, instead absorbing non-medical supervision and socialization into Personal Care Aide (PCA) services and the participant-directed Services My Way program. For individuals with intellectual disabilities, the Department on Disability Services (DDS) Developmental Disabilities Administration (DDA) covers a distinct Companion Services under the IDD Waiver.
Prospective providers cannot simply submit an application to bill Medicaid for these services. Approval requires attending a mandatory, ad-hoc quarterly information session hosted by the Long Term Care Administration (LTCA), followed by a formal Letter of Intent (LOI) submitted within 10 business days to secure a pre-approval notice before the Provider Data Management System (PDMS) will even accept an enrollment packet.
1. Service Definition and Scope
Because the District of Columbia does not use the term Adult Companion Services in its EPD Waiver, providers deliver these supports through Personal Care Aide (PCA) services or the Services My Way program. These services provide assistance with activities of daily living, socialization, and non-medical supervision to prevent institutionalization.
Under the DDA IDD Waiver, Companion Services are explicitly defined as non-medical care, supervision, and socialization provided to an adult. Providers must clearly identify which waiver they are targeting, as the scope and allowable tasks differ significantly between DHCF's aging population and DDS's IDD population.
- EPD Waiver PCA Scope: Includes assistance with grooming, dressing, eating, toileting, and general supervision to ensure safety in the home.
- Services My Way Scope: A participant-directed option allowing beneficiaries to hire friends or relatives (excluding spouses or legally responsible relatives) for non-medical care and companionship.
- IDD Waiver Companion Scope: Focuses on community integration, socialization, and supervision for individuals with intellectual and developmental disabilities.
- Excluded Activities: Companion and PCA services do not cover skilled nursing tasks, wound care, or infusions.
- Setting Limitations: Services may be provided in the participant's home, an adult foster care home, or an assisted living residence.
- Financial Management: For Services My Way, a designated Financial Management Services (FMS) agency handles tax withholding and caregiver payments.
2. Regulatory and Oversight Agencies
Multiple District of Columbia agencies oversee the provision of HCBS waivers, depending on the target population. The Department of Health Care Finance (DHCF) is the single state Medicaid agency responsible for overall waiver administration and provider enrollment.
For the EPD Waiver, DHCF's Long Term Care Administration (LTCA) manages provider approvals, while the Department of Aging and Community Living (DACL) assists with case management. For the IDD Waiver, the Department on Disability Services (DDS) Developmental Disabilities Administration (DDA) manages provider certification.
- Department of Health Care Finance (DHCF): Administers the Medicaid program and oversees the EPD Waiver (https://dhcf.dc.gov).
- DHCF Long Term Care Administration (LTCA): Coordinates mandatory provider information sessions and issues LOI pre-approvals (https://dhcf.dc.gov/page/becoming-epd-waiver-provider).
- Department of Aging and Community Living (DACL): Supports EPD Waiver participants and coordinates community resources (https://dacl.dc.gov).
- Department on Disability Services (DDS): Houses the DDA which certifies providers for the IDD Waiver (https://dds.dc.gov).
- DC Health: Regulates and licenses Home Care Agencies through the Division of Community Hygiene and Health Regulation and Licensing Administration (https://dchealth.dc.gov).
- Maximus: DHCF's provider enrollment vendor managing the Provider Data Management System (https://www.dcpdms.com).
3. Gatekeeping Prerequisites: Who Can Even Apply
The District of Columbia employs a strict, multi-step gatekeeping process for new EPD and IDD Waiver providers. A provider cannot simply create an account in the Medicaid portal and submit an application; the system requires a pre-approval notice uploaded with the packet.
For the EPD Waiver, DHCF/LTCA requires attendance at a mandatory information session, which is only held quarterly on an ad hoc basis. Providers must request to attend by demonstrating an exigent need, making open enrollment effectively closed unless DHCF identifies a network shortage.
- Mandatory Information Session: Prospective EPD providers must attend a formal session coordinated by LTCA, requiring prior approval from DHCF leadership to even register.
- Letter of Intent (LOI): Must be submitted via a specific Smartsheet link within 10 business days of attending the mandatory information session.
- Proof of Incorporation: The LOI must include documented proof of business incorporation specifically within the District of Columbia.
- LTCA Pre-Approval Notice: Required before initiating the EPD-Waiver application in PDMS; applications without this notice are rejected.
- DDA Pre-Approval Notice: Required for IDD/IFS Waiver applicants; obtained by contacting [email protected].
- Financial Viability Assessment: DHCF-ORRFA conducts a revised financial review as part of the pre-enrollment screening.
4. Licensure and Certification Requirements
To provide PCA services under the EPD Waiver, agencies must be licensed as a Home Care Agency (HCA) by DC Health. This licensure process involves submitting policies, procedures, and passing an initial site survey conducted by the Health Regulation and Licensing Administration.
Providers targeting the IDD Waiver for Companion Services must undergo a separate certification process through the Department on Disability Services (DDS) Provider Resource Management Unit (PRMU) before they can apply for Medicaid enrollment.
- Home Care Agency (HCA) License: Issued by DC Health, required for agencies deploying Personal Care Aides in the District.
- DDA Provider Certification: Required for agencies providing Companion Services under the IDD Waiver, involving a distinct readiness review by DDS.
- Certificate of Need (CON): DC Health requires a CON or a formal exemption letter for certain new health facilities and home care agencies.
- Local Business License: A Basic Business License (BBL) from the DC Department of Licensing and Consumer Protection (DLCP) is required.
- Site Visit Requirement: DHCF's vendor, Maximus, conducts structured pre- and post-enrollment site visits for all EPD waiver providers.
- Key Personnel Requirements: The agency administrator, owner, and quality assurance director must be identified and vetted during licensure.
5. Medicaid Provider Enrollment
All Medicaid provider enrollment in the District of Columbia is processed through the Provider Data Management System (PDMS) web portal, managed by Maximus. Providers have exactly 90 days to submit their application in PDMS after receiving their LOI pre-approval from LTCA.
Providers must select the correct application type in PDMS. EPD Waiver agencies select the 'EPD-Waiver' application, while IDD providers select 'IDD/IFS Waiver'. Individual aides working through an agency or the participant-directed program must also enroll using specific application types.
- Provider Data Management System (PDMS): The mandatory online enrollment portal for DC Medicaid (https://www.dcpdms.com).
- EPD-Waiver Application: The specific PDMS application type for agencies providing PCA services under the aging waiver.
- IDD/IFS Waiver Application: The specific PDMS application type for agencies providing Companion Services under the DDA waiver.
- PCA Aide Application: Individual Personal Care Assistant Aides working through a Home Health Agency or EPD Provider must enroll individually.
- PDW Application: Participant Directed Workers working through Services My Way must enroll using this specific application type.
- EFT Application: All new and re-enrolling providers must complete and submit an Electronic Funds Transfer application to receive payments.
6. Staffing, Training and Background Checks
Direct care workers providing socialization and supervision must meet strict District of Columbia training and background requirements. For EPD Waiver PCA services, staff must hold a valid Home Health Aide (HHA) or PCA certification recognized by DC Health.
Participant-directed workers under Services My Way have slightly more flexible training requirements but must still pass comprehensive background screenings. All waiver staff must maintain current CPR and First Aid certifications.
- PCA Certification: Staff providing EPD Waiver personal care must complete a DC Health-approved training program and hold active certification.
- Criminal Background Checks: Mandatory fingerprint-based background checks through the DC Metropolitan Police Department for all direct care staff.
- OIG Exclusion Screening: Agencies must screen all employees and contractors against the federal LEIE and DC Medicaid exclusion lists monthly.
- CPR and First Aid: All direct care workers must maintain active, in-person CPR and First Aid certifications.
- Participant-Directed Exclusions: Spouses and legally responsible relatives are strictly prohibited from being hired as paid caregivers under Services My Way.
- In-Service Training: Agencies must provide and document annual continuing education for all PCAs and Companion staff as dictated by DC Health regulations.
7. Documentation, Policies and Records
District of Columbia HCBS providers must maintain comprehensive records that align with the beneficiary's Person-Centered Service Plan (PCSP). DHCF requires strict adherence to Electronic Visit Verification (EVV) mandates for all personal care and companion-type services.
Agencies must also maintain detailed incident management policies. Any critical incidents, such as falls, suspected abuse, or unauthorized wandering, must be reported to DHCF or DDS within mandated timeframes.
- Person-Centered Service Plan (PCSP): All delivered services must map directly to the goals and authorized hours in the participant's PCSP.
- Electronic Visit Verification (EVV): Mandatory for PCA and Companion services; providers must use the state-sponsored system or a compliant alternate vendor.
- Daily Progress Notes: Staff must document the specific activities performed, the participant's response, and the exact start and end times of the shift.
- Incident Reporting: Critical incidents must be reported to the appropriate oversight agency (DACL, DHCF, or DDS) within 24 hours of discovery.
- Financial Records: Agencies must maintain auditable financial records to satisfy the DHCF-ORRFA Financial Viability Assessment requirements.
- Record Retention: Medicaid service and billing records must be retained for a minimum of ten years under DC regulations.
8. Billing, Rates and Claims
Reimbursement for EPD and IDD Waiver services is processed through the DC Medicaid MMIS, with claims submitted via the PDMS portal or a clearinghouse. Services are not entitlements; they are capped by the waiver's approved slots and the individual's authorized budget.
Before any billing can occur, the participant must have a completed Prescription Order Form (POF) from a DC Medicaid-enrolled physician or APRN, followed by a functional needs assessment conducted by Liberty Healthcare to confirm Nursing Facility Level of Care (NFLOC).
- Prescription Order Form (POF): Must be completed by a physician/APRN and submitted to Liberty Healthcare to initiate the functional assessment (https://dhcf.dc.gov/publication/electronic-prescription-order-form).
- Liberty Healthcare Assessment: Conducts the functional needs assessment scoring ADLs and cognition; a score of 9 or higher indicates NFLOC.
- Prior Authorization: All waiver services require an active prior authorization on file in the MMIS before claims will pay.
- Billing Codes: PCA services are typically billed using HCPCS code T1019, though providers must verify current codes in the DHCF fee schedule.
- Claim Submission Window: DC Medicaid generally requires claims to be submitted within 365 days from the date of service.
- Participant-Directed Billing: Handled entirely by the designated Financial Management Services (FMS) agency, not the individual caregiver.
9. Approval Sequence and Timeline
Becoming a provider in the District of Columbia is a lengthy process due to the ad hoc nature of the mandatory information sessions. Providers cannot control the timeline for Step 1, as they must wait for LTCA to announce a session and approve their attendance request.
Once the session is attended, the timeline becomes strictly regulated: 10 days to submit the LOI, 10 days for LTCA to respond, and 90 days to submit the PDMS application. The entire process, including DC Health licensure and Maximus site visits, typically takes 6 to 12 months.
- Step 1: Request and attend the ad hoc quarterly LTCA Mandatory Information Session.
- Step 2: Submit the Letter of Intent (LOI) via Smartsheet within 10 business days of the session.
- Step 3: Receive LTCA pre-approval notice and application checklist within 10 business days of LOI submission.
- Step 4: Submit the complete enrollment application through PDMS (www.dcpdms.com) within 90 days of receiving the pre-approval.
- Step 5: Maximus conducts an initial desk review to ensure all required documents, including the pre-approval notice, are attached.
- Step 6: Maximus conducts the mandatory pre-enrollment site visit before forwarding the finalized packet to DHCF for final approval.
10. Common Denials and Survey Findings
The most frequent cause for application rejection in the District of Columbia is attempting to bypass the gatekeeping steps. Applications submitted in PDMS without the official LTCA or DDA pre-approval notice are immediately denied by the enrollment vendor.
During post-enrollment site visits and audits, DHCF frequently cites providers for failing to properly implement Electronic Visit Verification (EVV) or for deploying staff whose background checks or CPR certifications have lapsed.
- Missing Pre-Approval: Submitting a PDMS application without the required LTCA or DDA pre-approval letter results in automatic rejection.
- Expired 90-Day Window: Failing to submit the PDMS application within 90 days of receiving the LOI approval forces the provider to restart the process.
- EVV Non-Compliance: Audits frequently penalize agencies for manual timesheet overrides or failing to capture GPS data at clock-in/out.
- Unqualified Staff: Deploying PCAs who have not completed the DC Health-approved training or whose background checks are incomplete.
- Incomplete LOI: Submitting an LOI that fails to demonstrate an understanding of the relationship between Medicaid State Plan services and EPD Waiver services.
- Financial Viability Failure: Failing the DHCF-ORRFA financial assessment due to insufficient operating capital or poor financial documentation.
11. Key Contacts and Resources
Prospective providers must rely on official District of Columbia portals and help desks to navigate the enrollment process. Informal inquiries via email or phone regarding application status are not accepted by DHCF once the formal review process begins.
The Maximus Customer Service Center is the primary contact for technical issues within the PDMS portal, while DHCF LTCA handles programmatic questions prior to application submission.
- DHCF Long Term Care Administration (LTCA): [email protected] or 202-442-9533 for EPD mandatory requirements (https://dhcf.dc.gov).
- DDA Provider Enrollment: [email protected] for IDD/IFS Waiver pre-approval notices (https://dds.dc.gov).
- PDMS Customer Service Center: Maximus help desk at 844-218-9700 or [email protected] for portal technical support (https://www.dcpdms.com).
- DC Health Licensing: For Home Care Agency licensure requirements and regulations (https://dchealth.dc.gov).
- Liberty Healthcare: For questions regarding the Prescription Order Form and functional needs assessments.
- Electronic Prescription Order Form: Official DHCF form required to initiate waiver assessments (https://dhcf.dc.gov/publication/electronic-prescription-order-form).
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