Idaho - Adult Companion Services — Licensing, Medicaid Enrollment and Startup Requirements

Last reviewed: 2026-08-15

In Idaho, Adult Companion Services are defined under the Aged and Disabled (A&D) Medicaid Waiver as in-home services providing non-medical care, supervision, and socialization to functionally impaired adults. These services ensure the safety and well-being of individuals who cannot be left alone due to frail health, a tendency to wander, or an inability to respond to emergencies, allowing them to remain safely in their communities.

The single biggest structural barrier to entry for this service in Idaho is the mandatory completion of the Prospective Home and Community Based Services (HCBS) Provider Toolkit. While Idaho does not require a Certificate of Need (CON) or impose a moratorium on new agencies, the Idaho Department of Health and Welfare (IDHW) will not accept a Medicaid enrollment application for a Personal Assistance Agency (PAA) until this comprehensive toolkit is completed and the agency passes a readiness review demonstrating strict compliance with the HCBS Settings Rule.

1. Service Definition and Scope

Under Idaho Administrative Code IDAPA 16.03.26.542, Companion Services are authorized under the Aged and Disabled (A&D) Waiver. The service is designed to provide non-medical supervision and socialization for adults who require an on-site presence to ensure their health and safety.

This service is strictly non-medical. Providers may assist with incidental housekeeping tasks, but they are prohibited from performing hands-on nursing care, skilled medical services, or tasks that fall under the distinct definition of attendant care or homemaker services.

• Target Population: Functionally impaired adults enrolled in the Idaho Aged and Disabled (A&D) Waiver.
• Covered Activities: Non-medical care, supervision, socialization, and incidental housekeeping.
• Excluded Activities: Hands-on nursing care, medication administration, and skilled medical services.
• Service Setting: The participant's private home or an HCBS-compliant community setting.
• Governing Regulation: Idaho Administrative Code IDAPA 16.03.26.542.

2. Regulatory and Oversight Agencies

The Idaho Department of Health and Welfare (IDHW) is the primary state agency responsible for overseeing Companion Services. Within IDHW, the Division of Medicaid administers the A&D Waiver and sets provider policy.

Medicaid enrollment and claims processing are managed by Gainwell Technologies, the state's fiscal agent, through the Idaho Medicaid Health PAS OnLine system. Quality assurance and compliance audits are conducted by the IDHW Bureau of Long Term Care (BLTC).

• Primary Agency: Idaho Department of Health and Welfare (IDHW).
• Waiver Authority: IDHW Division of Medicaid.
• Compliance Oversight: IDHW Bureau of Long Term Care (BLTC) Quality Assurance.
• Background Checks: IDHW Criminal History Unit (CHU).
• Fiscal Agent: Gainwell Technologies (operates the Health PAS OnLine portal).

3. Gatekeeping Prerequisites: Who Can Even Apply

Idaho does not utilize a Certificate of Need (CON) program for home and community-based services, nor are there currently any active moratoria or closed network procurements (RFPs) blocking new Companion Services providers. The network is open to any qualified applicant.

However, a strict structural precondition exists: prospective providers must complete the Prospective Home and Community Based Services (HCBS) Provider Toolkit. This toolkit acts as a mandatory pre-application gate; IDHW's provider enrollment vendor will reject any application that does not include proof of its completion and adherence to HCBS setting qualities.

• Certificate of Need (CON): None exists for HCBS companion services in Idaho.
• Network Moratoria: None; open enrollment is permitted year-round.
• Mandatory Pre-Application Step: Completion of the Prospective HCBS Provider Toolkit.
• Business Registration: Must be registered and in good standing with the Idaho Secretary of State.
• NPI Requirement: Must obtain a Type 2 National Provider Identifier (NPI) prior to initiating the application.

4. Licensure and Certification Requirements

Idaho does not issue a distinct "Companion Services License." Instead, providers offering in-home companion care operate under Medicaid certification as a Personal Assistance Agency (PAA). The Medicaid enrollment process itself serves as the operational approval authority.

If a provider intends to offer companion services within a congregate or facility-based setting that they own or operate, they must first obtain a Residential Assisted Living Facility (RALF) license from the IDHW Division of Licensing and Certification. For standard in-home agencies, the PAA designation is sufficient.

• Licensure Type: No specific state license for standalone in-home companion care; operates under PAA Medicaid certification.
• Alternative Licensure: Residential Assisted Living Facility (RALF) license required only if services are provided in a provider-owned congregate setting.
• HCBS Settings Compliance: Must demonstrate compliance with the 2019 Idaho Statewide Transition Plan for federally required setting qualities.
• Insurance Requirements: Must maintain general liability, professional liability, and workers' compensation insurance.
• Operating Guidelines: Must adhere to IDHW Division of Medicaid rules for A&D Waiver providers.

5. Medicaid Provider Enrollment

Provider enrollment is conducted entirely online through the Idaho Medicaid Health PAS OnLine portal. Applicants must first register for a Trading Partner Account (TPA) to access the system and submit their application.

During enrollment, agencies must submit a signed Medicaid Provider Enrollment Agreement, a W-9, and the completed HCBS Provider Toolkit. Providers must ensure their taxonomy codes exactly match those registered with the National Plan and Provider Enumeration System (NPPES).

• Enrollment Portal: Idaho Medicaid Health PAS OnLine (www.idmedicaid.com).
• Provider Type: Enrolls under HCBS Waiver provider types (e.g., Personal Assistance Agency).
• Required Forms: Medicaid Provider Enrollment Agreement and W-9.
• System Access: Must register for a Trading Partner Account (TPA) prior to application submission.
• Application Fee: Subject to the CMS-mandated institutional provider application fee unless waived or already paid to Medicare.
• Revalidation: Required every 5 years per federal CMS guidelines.

6. Staffing, Training and Background Checks

All direct care staff providing Companion Services must pass a rigorous fingerprint-based background check through the IDHW Criminal History Unit (CHU) before they can have any contact with Medicaid participants.

Agencies are responsible for ensuring staff are trained on the specific needs outlined in each participant's Individualized Service Plan (ISP). Basic safety certifications, including CPR and First Aid, are standard requirements for HCBS direct care workers in Idaho.

• Background Checks: Mandatory fingerprint-based check through the IDHW Criminal History Unit (CHU) prior to client contact.
• Minimum Age: Direct care staff must typically be at least 18 years old.
• Basic Training: CPR and First Aid certification required for all direct care staff.
• Service Plan Training: Staff must be trained specifically on the Individualized Service Plan (ISP) of their assigned participant.
• OIG Exclusion: Agencies must screen all staff monthly against the federal OIG List of Excluded Individuals/Entities (LEIE).

7. Documentation, Policies and Records

IDHW requires Personal Assistance Agencies to maintain comprehensive administrative and client records. These records are subject to unannounced audits by the Bureau of Long Term Care Quality Assurance.

Providers must develop and enforce written policies covering participant intake, emergency response, and incident reporting. Daily service logs must explicitly detail the start and stop times of each visit and the specific companion activities provided.

• Service Plans: Must maintain a current copy of the participant's IDHW-approved Individualized Service Plan (ISP).
• Service Logs: Daily documentation requiring exact start/stop times, activities performed, and staff signatures.
• Incident Reporting: Written policies for reporting abuse, neglect, or critical incidents to IDHW within 24 hours.
• Emergency Plans: Documented emergency response and backup staffing protocols for each participant.
• Record Retention: Medicaid records must be retained for a minimum of 5 years from the date of service.

8. Billing, Rates and Claims

Claims for Companion Services are submitted electronically via the Idaho Medicaid Health PAS OnLine portal using the state's Medicaid Management Information System (MMIS). Services are reimbursed on a fee-for-service basis.

Providers cannot bill for services unless they have been prior-authorized by the regional IDHW waiver case manager and are explicitly listed in the participant's ISP. Billing must align with the specific HCPCS codes designated for the A&D Waiver.

• Billing System: Idaho Medicaid Health PAS OnLine (MMIS).
• Claim Format: Professional claims submitted via 837P electronic transactions or direct data entry.
• Prior Authorization: Services must be prior-authorized by the IDHW waiver case manager.
• HCPCS Codes: Billed using waiver-specific codes (e.g., S5135) as outlined in the IDHW fee schedule.
• Reimbursement Model: Fee-for-service based on 15-minute increments or per diem rates defined by the state.

9. Approval Sequence and Timeline

The end-to-end process to become an approved Companion Services provider in Idaho typically takes 60 to 90 days. The timeline is heavily dependent on the accurate completion of the HCBS Provider Toolkit and the speed of background check processing.

Once the application is submitted via Health PAS OnLine, IDHW and Gainwell Technologies conduct a readiness review. Upon approval, the provider is issued a Medicaid ID and can finalize their Trading Partner Account for billing.

• Step 1: Register business with Idaho Secretary of State and obtain EIN/NPI (1-2 weeks).
• Step 2: Complete the Prospective HCBS Provider Toolkit (1-3 weeks).
• Step 3: Submit Medicaid Provider Enrollment Application via Health PAS OnLine (Day 1).
• Step 4: IDHW and Gainwell Technologies review application and toolkit (30-45 days).
• Step 5: Receive Medicaid ID and finalize Trading Partner Account (TPA) (1 week).
• Total Estimated Timeline: 60 to 90 days depending on state processing volume.

10. Common Denials and Survey Findings

Enrollment applications are frequently delayed or denied due to mismatched taxonomy codes between the provider's NPI record and their Idaho Medicaid application. Failure to submit the mandatory HCBS Provider Toolkit is another primary cause for immediate rejection.

During post-enrollment quality assurance audits, IDHW frequently cites providers for inadequate documentation. Missing exact start and stop times on daily service logs or failing to secure CHU background clearance before a worker's first shift are common, severe findings.

• Enrollment Denial: Mismatched NPI taxonomy codes between the federal registry and the state application.
• Toolkit Rejection: Incomplete or missing Prospective HCBS Provider Toolkit submission.
• Audit Finding: Missing or incomplete daily service logs (e.g., missing exact start/stop times).
• Audit Finding: Failure to complete CHU background checks prior to a staff member's first day of client contact.
• Audit Finding: Providing and billing for services outside the scope of the approved Individualized Service Plan (ISP).

11. Key Contacts and Resources

Prospective providers should rely on the Idaho Medicaid Health PAS OnLine portal for all enrollment forms, provider handbooks, and billing guides. The portal is maintained by Gainwell Technologies on behalf of IDHW.

For specific policy questions regarding the Aged and Disabled Waiver or HCBS compliance, providers should contact the IDHW Bureau of Long Term Care Quality Assurance.

• Medicaid Enrollment Portal: Idaho Medicaid Health PAS OnLine (www.idmedicaid.com).
• Waiver Policy Contact: IDHW Bureau of Long Term Care (BLTCQA@dhw.idaho.gov).
• Background Checks: IDHW Criminal History Unit (CHU).
• Provider Handbook: Available via the Health PAS OnLine Provider Guide section.
• State Regulations: Idaho Administrative Code (IDAPA) Title 16, Chapter 03.

See all Idaho services · Idaho Medicaid consulting · book a consultation.