Georgia - Skilled Respite Service — Licensing, Medicaid Enrollment and Startup Requirements

Last reviewed: 2026-08-15

In Georgia, there is no standalone "Skilled Respite Service" license. Instead, providers delivering respite care that requires licensed nursing interventions must obtain a Private Home Care Provider (PHCP) license with a specific "Nursing Services" authorization from the Department of Community Health (DCH), or operate as a licensed Home Health Agency. These services are typically reimbursed through Medicaid HCBS waivers such as the New Options Waiver (NOW), Comprehensive Supports Waiver Program (COMP), and the Community Care Services Program (CCSP).

The single biggest structural barrier to entry is the bifurcated, gatekept enrollment process. Securing a PHCP license from DCH does not guarantee Medicaid waiver enrollment; to serve the primary IDD waiver populations, providers must secure a Letter of Agreement (LOA) from the Department of Behavioral Health and Developmental Disabilities (DBHDD), which strictly controls network access through mandatory forums, closed enrollment windows, and regional need assessments.

1. Service Definition and Scope

Because Georgia does not define "Skilled Respite" as a distinct facility or license type, it is regulated based on the clinical acuity of the tasks performed during the primary caregiver's absence. When respite requires interventions exceeding basic personal care—such as ventilator management, complex wound care, or tube feeding—it must be delivered by licensed nurses under an appropriately credentialed agency.

Under Georgia Medicaid waivers, this is typically billed as In-Home Respite combined with skilled nursing requirements, ensuring the participant's medical needs are met safely while providing temporary relief to the primary unpaid caregiver.

• Licensure Category: Private Home Care Provider (PHCP) with a Nursing Services authorization.
• Alternative Category: Home Health Agency (HHA), though this requires a Certificate of Need.
• Target Population: Individuals on NOW, COMP, CCSP, or SOURCE waivers requiring RN or LPN level care during caregiver absence.
• Scope of Practice: Clinical tasks are strictly governed by the Georgia Registered Professional Nurse Practice Act (O.C.G.A. Title 43, Chapter 26).
• Setting: Typically delivered in the participant's private residence (In-Home Respite).

2. Regulatory and Oversight Agencies

Oversight in Georgia is divided between the licensing body that ensures facility and agency safety, and the waiver operating agencies that manage the specific Medicaid populations.

Providers must maintain compliance with both the state licensing regulations and the specific policy manuals of the waiver programs they serve.

• Licensing Authority: DCH Healthcare Facility Regulation Division (HFRD) issues and monitors PHCP licenses.
• Medicaid Agency: Georgia Department of Community Health (DCH) Medical Assistance Plans oversees the GAMMIS system and overall Medicaid compliance.
• Waiver Operator (IDD): Department of Behavioral Health and Developmental Disabilities (DBHDD) operates the NOW and COMP waivers.
• ASO/Credentialing: The Georgia Collaborative ASO manages the DBHDD provider network, credentialing, and enrollment forums.
• Waiver Operator (Aging/Physical): DCH Division of Aging Services (DAS) manages the CCSP waiver.

3. Gatekeeping Prerequisites: Who Can Even Apply

Georgia heavily restricts access to its Medicaid HCBS waiver networks. A valid state license is merely a baseline; structural preconditions block applicants from even submitting a Medicaid enrollment application without prior network approval.

Providers cannot simply enroll in GAMMIS for waiver services at will. They must navigate specific procurement and network adequacy gates enforced by the waiver operating agencies.

• DBHDD Network Access: Applicants must register for and attend a mandatory New Provider Enrollment Forum presented by the Georgia Collaborative ASO before initiating any NOW/COMP waiver application.
• Enrollment Windows: DBHDD frequently utilizes closed enrollment periods or targeted RFPs based on regional network adequacy; open enrollment is not guaranteed.
• Letter of Agreement (LOA): Providers must secure an LOA from DBHDD to provide NOW/COMP waiver services, which serves as the absolute prerequisite for GAMMIS enrollment.
• Certificate of Need (CON) Barrier: If a provider chooses to operate as a Home Health Agency rather than a PHCP to deliver skilled services, they must first secure a CON from the DCH Office of Health Planning—a highly restrictive, need-based legal barrier.
• Operating History: DBHDD typically requires new waiver applicants to demonstrate prior organizational experience in healthcare or HCBS delivery before granting an LOA.

4. Licensure and Certification Requirements

To provide skilled respite without triggering the Home Health CON requirement, agencies must obtain a Private Home Care Provider (PHCP) license from DCH HFRD.

Crucially, the agency must explicitly apply for and be granted the "Nursing Services" provision on their PHCP license; a standard PHCP license limited to personal care or companion tasks is insufficient for skilled respite.

• Application Form: DCH HFRD Private Home Care Provider Initial License Application.
• Licensure Rule: Subject to the Rules and Regulations for Private Home Care Providers, Chapter 111-8-65.
• Service Authorization: Must explicitly check and qualify for the "Nursing Services" authorization on the PHCP application.
• Fees: $500 initial application fee for PHCP licensure.
• Provisional Status: DCH issues a provisional license (valid up to 90 days) pending a satisfactory initial on-site survey by HFRD.

5. Medicaid Provider Enrollment

Once licensed by HFRD and approved by the waiver operating agency (e.g., holding a DBHDD LOA), providers must enroll in the Georgia Medicaid Management Information System (GAMMIS).

Because skilled respite involves nursing services, DCH classifies these applications under Moderate to High categorical risk, triggering enhanced screening protocols.

• System: Georgia Medicaid Management Information System (GAMMIS) Provider Portal.
• Risk Category: Moderate to High categorical risk, requiring unannounced pre-enrollment or post-enrollment site visits.
• NPI Requirement: A Type 2 (Organizational) National Provider Identifier (NPI) is required.
• Application Fee: Subject to the CMS standard institutional application fee (e.g., $709 for 2024/2025), unless waived by prior Medicare enrollment.
• Revalidation: Providers must revalidate their Medicaid enrollment every 3 to 5 years per 42 CFR 455.414; failure results in immediate suspension.

6. Staffing, Training and Background Checks

Skilled respite requires clinical oversight and direct care by licensed nursing professionals. Unlicensed direct support professionals (DSPs) cannot perform skilled nursing tasks.

Georgia mandates strict background screening and credential verification for all personnel entering a waiver participant's home.

• Clinical Director: The agency must employ a Georgia-licensed Registered Nurse (RN) to supervise all skilled respite care and develop nursing care plans.
• Direct Care Staff: Must hold active, unencumbered Georgia LPN or RN licenses verified via the Georgia Board of Nursing.
• Background Checks: Mandatory fingerprint-based criminal history checks processed through the Georgia Applicant Processing Service (GAPS).
• CPR/First Aid: All direct care staff must maintain current, in-person CPR and First Aid certification.
• TB Screening: Mandatory tuberculosis screening for all patient-facing staff prior to initial client contact.

7. Documentation, Policies and Records

Providers must maintain rigorous clinical and administrative records that satisfy both DCH HFRD licensing surveyors and DBHDD/Medicaid auditors.

Documentation must clearly delineate the skilled nature of the respite provided to justify the higher reimbursement rates associated with nursing-level care.

• Individual Service Plan (ISP): Care must strictly align with the DBHDD or DCH approved ISP, detailing the exact hours and scope of respite authorized.
• Nursing Care Plan: The supervising RN must develop, sign, and periodically update a specific nursing care plan for the skilled interventions.
• Service Notes: Must include date, start/stop times, specific skilled tasks performed, patient response, and the nurse's signature with credentials.
• Incident Reporting: Critical incidents must be reported via the state's HCBS Incident Reporting System within 24 hours.
• Record Retention: Clinical and billing records must be retained for a minimum of 6 years from the date of service.

8. Billing, Rates and Claims

Claims for skilled respite are submitted electronically through GAMMIS. Providers must ensure they use the correct HCPCS codes and modifiers that denote nursing-level care.

Georgia has implemented Electronic Visit Verification (EVV) for in-home services, meaning all in-home respite shifts must be logged electronically at the point of care.

• Billing Portal: Claims are submitted electronically via the GAMMIS web portal or an approved clearinghouse.
• Billing Codes: Typically billed using HCPCS codes like T1005 (Respite care services, 15 minutes) with specific modifiers (e.g., TD for RN, TE for LPN) as dictated by the waiver manual.
• Prior Authorization: 100% of waiver skilled respite requires prior authorization (PA) loaded into GAMMIS by the waiver operating agency.
• EVV Requirement: Subject to Electronic Visit Verification (EVV) via the Georgia Tellus/Netsmart system; manual timesheets are not accepted for claims generation.
• Timely Filing: Claims must generally be submitted within 6 months of the date of service to avoid denial.

9. Approval Sequence and Timeline

Becoming a skilled respite provider in Georgia is a sequential, multi-agency process that cannot be expedited. Providers must secure licensing before seeking waiver approval, and waiver approval before Medicaid enrollment.

The entire process from business formation to billing the first claim typically takes 6 to 12 months, heavily dependent on DBHDD enrollment windows.

• Step 1: Obtain an NPI and register the business with the Georgia Secretary of State (1-2 weeks).
• Step 2: Submit the PHCP application to DCH HFRD and pass the initial review/survey to obtain a provisional license (60-90 days).
• Step 3: Attend the DBHDD New Provider Enrollment Forum and submit the LOA application (timeline varies based on open windows).
• Step 4: Submit the GAMMIS Medicaid Enrollment application once the LOA is secured (30-60 days).
• Step 5: Complete the unannounced pre-enrollment site visit and GAPS fingerprinting (adds 14-45 days).

10. Common Denials and Survey Findings

DCH HFRD and DBHDD conduct regular audits and surveys. Failure to maintain strict boundaries between personal care and skilled nursing is a frequent source of citations.

Medicaid enrollment applications are routinely rejected for minor clerical mismatches between the state license, NPI registry, and GAMMIS application.

• Unapproved Tasks: Performing skilled nursing tasks under a PHCP license that is only authorized for personal care or companion services.
• Lapsed Credentials: Failure to verify ongoing RN/LPN licensure or allowing CPR certifications to expire.
• EVV Non-Compliance: Missing EVV entries or excessive manual edits failing to match billed claims in GAMMIS.
• Inadequate RN Supervision: Lack of documented RN supervisory visits or failure to update the nursing care plan as the participant's acuity changes.
• Background Check Gaps: Allowing staff to provide care before the GAPS fingerprint clearance is fully returned and approved by the state.

11. Key Contacts and Resources

Providers must actively monitor updates from DCH and DBHDD, as waiver policies and licensing rules are subject to frequent revision.

Utilize the official state portals for all applications, background checks, and billing inquiries.

• DCH HFRD: Healthcare Facility Regulation Division for PHCP licensing applications and rule manuals.
• GAMMIS: Georgia Medicaid Management Information System (mmis.georgia.gov) for provider enrollment and claims.
• Georgia Collaborative ASO: Manages DBHDD provider enrollment, forums, and credentialing (georgiacollaborative.com).
• DBHDD: Department of Behavioral Health and Developmental Disabilities for NOW/COMP waiver policies.
• GAPS: Georgia Applicant Processing Service for mandatory fingerprint-based background checks.

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