Hawaii - Housing Stabilization — Licensing, Medicaid Enrollment and Startup Requirements

Last reviewed: 2026-09-09

The Hawaii Department of Human Services (DHS) Med-QUEST Division funds tenancy support through Community Integration Services (CIS) under the state's QUEST Integration 1115 Waiver demonstration. This service provides high-needs Medicaid beneficiaries with pre-tenancy assistance, such as housing search and application help, alongside tenancy-sustaining supports like landlord mediation and retention planning to prevent homelessness.

Because Hawaii delegates the administration of its HCBS waiver benefits to managed care organizations, state Medicaid enrollment alone does not grant the ability to bill for this service. An applicant must secure a network contract and credentialing approval from at least one of the QUEST Integration health plans before any service authorizations or reimbursements can be issued.

1. Service Definition and Scope

In Hawaii, housing stabilization is formally categorized as Community Integration Services (CIS) within the QUEST Integration program. The service is bifurcated into two distinct phases: pre-tenancy supports to help members secure housing, and tenancy-sustaining supports to help them maintain it.

CIS is strictly an administrative and supportive service. It does not cover the cost of room and board, rent, or physical facility modifications, which are handled under separate waiver authorities or housing assistance programs.

• Pre-Tenancy Supports: Includes conducting housing assessments, assisting with housing applications, and helping members secure necessary documentation.
• Tenancy Sustaining Supports: Includes landlord mediation, lease compliance education, and developing housing retention plans.
• Target Population: High-risk, high-utilizing Medicaid enrollees who are homeless or at imminent risk of institutional placement.
• Service Limitations: Cannot duplicate case management services already provided under other Medicaid authorities.
• Funding Authority: Authorized under Hawaii's Section 1115 QUEST Integration Demonstration Waiver.

2. Regulatory and Oversight Agencies

The primary oversight body for Medicaid services in Hawaii is the Department of Human Services (DHS), specifically the Med-QUEST Division (MQD). MQD manages the 1115 waiver and oversees the managed care plans that directly administer the benefits.

Because CIS is an unlicensed community-based service, the Department of Health's Office of Health Care Assurance (OHCA) does not issue a facility or agency license for it. Instead, oversight is delegated to the QUEST Integration health plans.

• Hawaii Med-QUEST Division (MQD): Oversees the Medicaid program, provider enrollment, and the 1115 waiver (https://medquest.hawaii.gov/).
• Centers for Medicare & Medicaid Services (CMS): Grants federal approval for the QUEST Integration 1115 Waiver (https://www.medicaid.gov/medicaid/section-1115-demo/demonstration-and-waiver-list/81451).
• Hawaii Department of Commerce and Consumer Affairs (DCCA): Registers all business entities operating in the state (https://cca.hawaii.gov/).
• QUEST Integration Health Plans: The managed care organizations (e.g., AlohaCare, HMSA) that contract with providers and authorize services (https://medquest.hawaii.gov/en/members-applicants/health-plans.html).

3. Gatekeeping Prerequisites: Who Can Even Apply

Hawaii does not utilize a traditional open-enrollment fee-for-service model for HCBS waiver services. The structural precondition for operating as a CIS provider is securing a network contract with a QUEST Integration Managed Care Organization (MCO).

If an MCO determines its network is adequate for a specific geographic area or service, it may refuse to contract with new providers, effectively blocking an agency from delivering billable services regardless of their state Medicaid enrollment status.

• MCO Contracting Requirement: Providers must secure a contract with one or more QUEST Integration MCOs to receive authorizations and bill for services.
• Business Registration: Applicants must register their business entity with the Hawaii Department of Commerce and Consumer Affairs (DCCA) prior to applying.
• Federal Identifiers: Agencies must obtain an Employer Identification Number (EIN) and a Type 2 National Provider Identifier (NPI).
• HCBS Settings Rule Compliance: Providers must demonstrate the ability to deliver services in fully integrated community settings prior to the delivery of service.

4. Licensure and Certification Requirements

Hawaii does not have a specific statutory license for Housing Stabilization or Community Integration Services agencies. The state's Office of Health Care Assurance (OHCA) licenses residential and inpatient facilities, but not administrative tenancy support agencies.

Instead of a license, providers achieve certification through the Med-QUEST provider enrollment process and subsequent credentialing by the QUEST Integration health plans, which verify the agency's operational policies and staff qualifications.

• Licensure Exemption: No specific state license is required from OHCA for non-medical tenancy support services.
• Insurance Requirements: Providers must maintain general liability, professional liability, and worker's compensation insurance.
• Policy Development: Agencies must develop participant-centered policies and procedures for service delivery, safety, and documentation.
• MCO Credentialing: Health plans conduct their own credentialing reviews to ensure the provider meets waiver standards before executing a contract.

5. Medicaid Provider Enrollment

All providers must enroll with the Hawaii Med-QUEST Division before they can contract with an MCO. This is completed through the state's Medicaid provider enrollment system.

During enrollment, the agency must identify as an HCBS provider and submit proof of business registration, insurance, and federal identifiers.

• Enrollment Portal: Applications are submitted to the Med-QUEST Division.
• Required Documentation: Articles of Incorporation, IRS EIN confirmation, and NPI confirmation.
• Provider Agreement: Applicants must sign the Medicaid HCBS Provider Agreement, acknowledging compliance with state and federal regulations.
• Revalidation: Medicaid enrollment must typically be revalidated every five years.

6. Staffing, Training and Background Checks

While CIS does not require clinical licensure (such as an RN or LCSW) for direct support staff, agencies must ensure personnel possess the necessary experience in housing navigation and social services.

All staff interacting with Medicaid beneficiaries must pass comprehensive background checks and complete mandatory training on the HCBS Final Rule and person-centered planning.

• Background Checks: All direct support staff must clear state and federal criminal background screenings.
• Staff Qualifications: Direct workers typically need a high school diploma and experience in human services, case management, or housing navigation.
• Mandatory Training: Staff must complete HIPAA confidentiality, participant rights, and emergency response training.
• HCBS Final Rule Training: Staff must be trained on maximizing participant independence and community integration.

7. Documentation, Policies and Records

Providers must maintain rigorous documentation to justify the services billed to the MCOs. Every service delivered must tie directly to goals outlined in the participant's Individualized Service Plan (ISP).

Agencies are required to maintain daily service logs, grievance policies, and critical incident reporting procedures in accordance with Med-QUEST and MCO standards.

• Service Alignment: All tenancy supports must be specified in the participant's ISP.
• Daily Logs: Providers must maintain detailed daily service logs documenting the specific interventions provided and time spent.
• Grievance System: Agencies must implement a formal grievance and appeals system consistent with 42 CFR Part 438, Subpart F.
• Record Retention: Medicaid records must generally be retained for a minimum of ten years.

8. Billing, Rates and Claims

Because CIS is managed under the QUEST Integration waiver, providers do not submit claims directly to the Med-QUEST fee-for-service system. All claims are routed to the authorizing MCO.

Rates and specific billing codes (often utilizing HCPCS codes like H0043 for supported housing) are established by the MCO contracts, though they must align with Med-QUEST's baseline fee schedules.

• Claims Submission: Claims are submitted directly to the contracted QUEST Integration MCO.
• Prior Authorization: All CIS services require prior authorization from the MCO based on the participant's ISP.
• Rate Determination: Reimbursement rates are negotiated and set within the MCO provider contract.
• Non-Duplication: Providers cannot bill for tenancy supports if the member is receiving identical case management services under another program.

9. Approval Sequence and Timeline

The pathway to becoming a billing provider involves multiple sequential steps, starting with business formation and ending with MCO contracting. The entire process can take several months.

Providers should not hire extensive staff or accept referrals until the final MCO contract is executed, as Med-QUEST enrollment alone does not guarantee network inclusion.

• Step 1: Register the business with the Hawaii DCCA and obtain an EIN and NPI (1-2 weeks).
• Step 2: Submit the Provider Enrollment Application to the Med-QUEST Division (30-90 days).
• Step 3: Apply for network inclusion and credentialing with one or more QUEST Integration MCOs (90-120 days).
• Step 4: Execute the MCO contract and configure billing systems for authorized HCPCS codes.

10. Common Denials and Survey Findings

Applications are most frequently stalled or denied during the MCO contracting phase rather than the state enrollment phase. MCOs may reject applicants if they determine their current network of CIS providers is sufficient.

During ongoing monitoring, providers often face corrective actions for failing to properly document how their services align with the participant's ISP or for violating HCBS settings requirements.

• Network Adequacy Denials: MCOs refusing to contract due to a lack of geographic or service-specific need.
• Documentation Failures: Audits revealing daily logs that do not match the billed time or ISP goals.
• HCBS Non-Compliance: Failing to demonstrate that services are provided in fully integrated community settings.
• Credentialing Lapses: Failure to maintain current background checks or insurance certificates for active staff.

11. Key Contacts and Resources

Prospective providers should rely on the Med-QUEST Division for state enrollment guidelines and the individual QUEST Integration health plans for contracting requirements.

Reviewing the current QUEST Integration RFP and MCO provider manuals is essential for understanding exact billing and documentation standards.

• Hawaii Med-QUEST Division: State Medicaid agency overseeing the 1115 waiver (https://medquest.hawaii.gov/).
• Hawaii Department of Commerce and Consumer Affairs (DCCA): For business registration (https://cca.hawaii.gov/).
• CMS Hawaii QUEST Integration Page: Federal waiver documents and approvals (https://www.medicaid.gov/medicaid/section-1115-demo/demonstration-and-waiver-list/81451).
• QUEST Integration Health Plans: Directory of MCOs for contracting inquiries (https://medquest.hawaii.gov/en/members-applicants/health-plans.html).

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