Georgia - Skilled Nursing Services — Licensing, Medicaid Enrollment and Startup Requirements

Last reviewed: 2026-09-09

The Georgia Department of Community Health (DCH) Healthcare Facility Regulation Division (HFRD) licenses the delivery of in-home RN and LPN care under the Private Home Care Provider (PHCP) or Home Health Agency (HHA) classifications. Medicaid reimburses these skilled nursing services through several Home and Community-Based Services (HCBS) waivers, including the Comprehensive Supports Waiver Program (COMP), New Options Waiver (NOW), Community Care Services Program (CCSP), Service Options Using Resources in a Community Environment (SOURCE), and the Georgia Pediatric Program (GAPP).

Applicants seeking to bill Medicaid for these services must first secure a Certificate of Need (CON) if applying as a Home Health Agency, or obtain a PHCP license and secure a waiver-specific operating agency recommendation—such as a DBHDD pre-approval for the COMP/NOW waivers—before submitting a Medicaid enrollment application through the GAMMIS portal.

1. Service Definition and Scope

In Georgia, HCBS Skilled Nursing Services consist of complex, specialized medical care delivered in the member's home or community setting by a licensed Registered Nurse (RN) or Licensed Practical Nurse (LPN). These services are strictly limited to tasks that fall outside the scope of personal care or companion services and must be medically necessary.

All skilled nursing interventions must be ordered by a physician, advanced practice registered nurse, or physician assistant, and documented in a formal, individualized Plan of Care. The scope varies slightly by waiver, with GAPP focusing on medically fragile children and COMP/NOW focusing on individuals with intellectual and developmental disabilities.

• Service Modality: Direct, in-home clinical care including assessments, medication administration, wound care, and ventilator management.
• Prescribing Authority: Services require a written order from a physician, APRN, or PA.
• RN Responsibilities: Initial comprehensive assessments, care plan development, and supervision of LPNs and aides.
• LPN Responsibilities: Routine skilled treatments and medication administration under the direct supervision of an RN.
• GAPP Specifics: Provides continuous or intermittent skilled nursing specifically for Medicaid-eligible children under 21 based on medical necessity.
• COMP/NOW Specifics: Provides skilled nursing to adults with I/DD to prevent institutionalization, requiring DBHDD prior authorization.

2. Regulatory and Oversight Agencies

The Georgia Department of Community Health (DCH) serves as the State Medicaid Agency and the primary licensing body for healthcare facilities. Within DCH, the Healthcare Facility Regulation Division (HFRD) issues the foundational licenses required to operate.

For specific waiver populations, DCH delegates day-to-day operational oversight to other state entities. The Department of Behavioral Health and Developmental Disabilities (DBHDD) manages the COMP and NOW waivers, while DCH directly manages GAPP, CCSP, and SOURCE.

• Licensing Agency: DCH Healthcare Facility Regulation Division (HFRD) (https://dch.georgia.gov/divisionsoffices/healthcare-facility-regulation).
• Medicaid Authority: DCH Medical Assistance Plans (https://medicaid.georgia.gov/).
• I/DD Waiver Operating Agency: Department of Behavioral Health and Developmental Disabilities (DBHDD) (https://dbhdd.georgia.gov/).
• Medicaid Enrollment Portal: Georgia Medicaid Management Information System (GAMMIS) (https://www.mmis.georgia.gov/portal/).
• Nursing Board: Georgia Board of Nursing (https://sos.ga.gov/georgia-board-nursing).

3. Gatekeeping Prerequisites: Who Can Even Apply

Georgia imposes strict structural prerequisites depending on the licensure pathway chosen. A provider must hold either a Home Health Agency (HHA) license or a Private Home Care Provider (PHCP) license to deliver skilled nursing in the home.

If a provider chooses the HHA pathway, they are subject to Georgia's Certificate of Need (CON) laws, which strictly limit the number of HHAs based on state-determined geographic need. If choosing the PHCP pathway, no CON is required, but the provider must secure waiver-specific approvals, such as DBHDD's Letter of Intent (LOI) process, before Medicaid enrollment is permitted.

• HHA Certificate of Need (CON): Required by DCH for Home Health Agencies; applications are routinely denied if the state health plan shows no unmet need in the county.
• PHCP Licensure: Required for non-HHA agencies providing nursing services; exempt from CON but restricted in certain Medicare/Medicaid billing scopes compared to HHAs.
• DBHDD Letter of Intent (LOI): Required prerequisite for COMP/NOW waiver enrollment; DBHDD only accepts LOIs during specific open enrollment windows.
• GAPP Provider Approval: Requires submission of a specific GAPP application packet to DCH prior to GAMMIS enrollment.
• Medicare Certification: Required for HHA licensure, but not strictly required for PHCPs billing only HCBS waivers.

4. Licensure and Certification Requirements

To operate as a Private Home Care Provider (PHCP) offering nursing services, agencies must apply through the DCH HFRD. The process involves a detailed application, submission of operational policies, and an initial on-site inspection.

Agencies must comply with the Rules and Regulations for Private Home Care Providers (Chapter 111-8-65). The license must specifically authorize the provision of 'Nursing Services' alongside any personal care or companion services.

• Regulatory Citation: Rules and Regulations for Private Home Care Providers, Chapter 111-8-65.
• Application Fee: $500 initial application fee for PHCP licensure.
• Administrator Qualifications: Must designate a qualified administrator with specific healthcare management experience.
• Nursing Director: Must employ or contract with a Georgia-licensed RN to oversee all clinical services.
• Surety Bond: May be required depending on the specific Medicaid waiver program requirements.
• On-Site Survey: HFRD conducts an initial licensing survey to verify policy compliance and physical office standards.

5. Medicaid Provider Enrollment

Once licensed, providers must enroll in Georgia Medicaid through the GAMMIS portal. The enrollment application serves as a single source for both fee-for-service Medicaid and Care Management Organization (CMO) credentialing.

Providers must select the appropriate Category of Service (COS) codes that match their licensure and the specific waivers they intend to bill. An application fee is required unless the provider has already paid it to Medicare or another state's Medicaid program.

• Enrollment Portal: GAMMIS Provider Enrollment Wizard.
• Application Fee: $731 (for 2024/2025, adjusted annually by CMS) required under 42 CFR 455.460.
• Required Documents: Copy of PHCP or HHA license, W-9, EFT authorization, and NPI verification.
• Category of Service: Must select specific COS codes for GAPP, COMP, or CCSP as applicable.
• Site Visit: DCH or its contractor conducts a pre-enrollment site visit for moderate and high-risk provider categories.
• Revalidation: Providers must revalidate their Medicaid enrollment every 3 to 5 years depending on risk category.

6. Staffing, Training and Background Checks

All personnel delivering skilled nursing services must hold active, unencumbered licenses from the Georgia Board of Nursing. Agencies are responsible for verifying credentials prior to employment and continuously monitoring license status.

Georgia law mandates comprehensive background checks for all owners, administrators, and direct care staff. This is processed through the Georgia Criminal Background Check System (GCHEXS).

• RN/LPN Licensure: Must hold a valid Georgia RN or LPN license or a multi-state compact license.
• Background Checks: Mandatory fingerprint-based national background checks via GCHEXS for all direct care staff.
• CPR/First Aid: All clinical staff must maintain current CPR and First Aid certifications.
• TB Testing: Annual tuberculosis screening required for all patient-facing staff.
• Supervision: LPNs must receive documented supervision by an RN at least every 60 days, or more frequently based on waiver rules.
• Waiver Training: Staff serving COMP/NOW participants must complete DBHDD-mandated developmental disability training modules.

7. Documentation, Policies and Records

Providers must maintain comprehensive clinical records for every Medicaid member served. Documentation must clearly demonstrate medical necessity, adherence to the physician's orders, and the specific skilled nature of the interventions provided.

Agencies must utilize standardized forms, such as the CMS-485 or state-specific waiver care plans, to document the Plan of Care. All nursing notes must be signed, dated, and align with the approved prior authorization.

• Plan of Care: Must be signed by the ordering physician and updated at least every 60 days.
• Clinical Notes: Detailed visit notes documenting vital signs, interventions, patient response, and time in/out.
• Medication Administration Record (MAR): Required for all patients receiving medication management services.
• Incident Reporting: Critical incidents must be reported to DCH and the waiver operating agency (e.g., DBHDD) within 24 hours.
• Record Retention: Clinical and billing records must be retained for a minimum of 6 years from the date of service.
• Emergency Preparedness: Must maintain and annually update a comprehensive disaster preparedness plan.

8. Billing, Rates and Claims

Skilled nursing services are billed to Georgia Medicaid using standard HCPCS codes, primarily T1002 for RN services and T1003 for LPN services. Claims are submitted electronically through the GAMMIS portal or via a clearinghouse.

Georgia mandates the use of Electronic Visit Verification (EVV) for all in-home personal care and home health care services. Providers must use the state-sponsored EVV system (Netsmart/Tellus) or an approved alternate vendor to capture visit data.

• Billing System: GAMMIS Web Portal for fee-for-service claims.
• Procedure Codes: T1002 (RN services, up to 15 minutes) and T1003 (LPN services, up to 15 minutes).
• Prior Authorization: All waiver nursing services require an approved Prior Authorization (PA) on file in GAMMIS before billing.
• EVV Requirement: Mandatory compliance with the 21st Century Cures Act using the Georgia EVV system.
• Rate Setting: Rates are established by DCH and published in the specific waiver provider manuals (e.g., COMP/NOW Part III manual).
• Timely Filing: Claims must generally be submitted within 6 months of the date of service.

9. Approval Sequence and Timeline

The pathway to becoming a billing provider is sequential and cannot be expedited. An agency must secure its physical location, obtain local business licenses, and hire key personnel before applying for state licensure.

Only after the HFRD license is in hand can the provider apply for waiver-specific approvals (like DBHDD enrollment) and finally submit the Medicaid enrollment application to GAMMIS.

• Step 1: Local Compliance: Obtain local business license and secure commercial office space.
• Step 2: State Licensure: Submit PHCP application to DCH HFRD (approx. 3-6 months for review and initial survey).
• Step 3: Waiver Approval: Apply to specific operating agency (e.g., DBHDD LOI process, 2-4 months).
• Step 4: Medicaid Enrollment: Submit GAMMIS application with license and waiver approvals (approx. 45-90 days).
• Step 5: EVV Registration: Register and train staff on the Netsmart/Tellus EVV system.
• Step 6: Prior Authorizations: Receive member referrals and secure PAs before initiating care.

10. Common Denials and Survey Findings

Licensure applications and Medicaid enrollments are frequently delayed or denied due to incomplete documentation or failure to meet strict personnel qualifications. HFRD will reject PHCP applications if the designated RN director lacks required experience.

During post-enrollment audits and surveys, DCH frequently cites providers for documentation failures, particularly regarding physician signatures and EVV compliance.

• Application Denial: Failure to pass the GCHEXS background check for owners or administrators.
• Enrollment Rejection: Mismatch between the legal business name on the license, IRS W-9, and GAMMIS application.
• Survey Citation: Expired or missing physician signatures on the 60-day Plan of Care.
• Survey Citation: Failure to document required RN supervisory visits for LPNs and aides.
• Claim Denial: Billing for services without a matching, verified EVV record.
• Claim Denial: Units billed exceed the amount authorized on the member's Prior Authorization.

11. Key Contacts and Resources

Providers must navigate multiple state portals and agency websites to maintain compliance. The DCH website houses licensure rules, while GAMMIS hosts provider manuals and billing updates.

For waiver-specific questions, providers should contact the respective operating agency directly, such as DBHDD for COMP/NOW or the DCH Medical Assistance Plans division for GAPP.

• DCH Healthcare Facility Regulation: https://dch.georgia.gov/divisionsoffices/healthcare-facility-regulation
• Georgia Medicaid (GAMMIS) Portal: https://www.mmis.georgia.gov/portal/
• DBHDD Provider Enrollment: https://dbhdd.georgia.gov/be-connected/community-provider-information
• Georgia Board of Nursing: https://sos.ga.gov/georgia-board-nursing
• Georgia EVV Information: https://medicaid.georgia.gov/programs/all-programs/electronic-visit-verification-evv
• GCHEXS Background Check System: https://dch.georgia.gov/divisionsoffices/healthcare-facility-regulation/georgia-criminal-background-check-system-gchexs

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