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

Last reviewed: 2026-08-15

In Indiana, Adult Companion Services provide non-medical supervision, socialization, and assistance to ensure the safety and well-being of adults living in their communities. Because Indiana does not issue a distinct facility or agency license specifically for "Adult Companion" providers, agencies must instead be certified directly by the Indiana Family and Social Services Administration (FSSA) and enroll as Home- and Community-Based Services (HCBS) waiver providers through the Indiana Health Coverage Programs (IHCP).

The single biggest structural barrier to entry for new providers is the 6-Month HCBS Waiver Provider Enrollment Moratorium effective August 1, 2026. Enacted by the IHCP to mitigate fraud, waste, and abuse, this moratorium strictly prohibits the enrollment of new providers for specified services under the PathWays for Aging, Health and Wellness, Community Integration and Habilitation (CIH), Traumatic Brain Injury (TBI), and Family Supports (FSW) waivers, effectively halting new market entries until the moratorium is lifted.

1. Service Definition and Scope

Adult Companion Services in Indiana are defined as non-medical care, supervision, and socialization provided to an adult waiver participant. These services are designed to assist individuals who require support to safely remain in a community setting rather than an institution.

Because Indiana does not license this service under a distinct statutory authority, it is governed by the general service definitions and provider standards of the specific Medicaid HCBS waivers that fund it. Providers must strictly separate companion services from hands-on medical care or personal care services.

• Service Scope: Non-medical supervision, socialization, and assistance with community activities for adult waiver participants.
• Excluded Activities: Hands-on nursing care, medication administration, or any services already covered by the Medicaid State Plan.
• Applicable Waivers: Funded primarily through the PathWays for Aging, Health and Wellness, Community Integration and Habilitation (CIH), Traumatic Brain Injury (TBI), and Family Supports (FSW) waivers.
• Setting Requirements: Services must be delivered in compliance with the CMS HCBS Settings Final Rule (42 CFR Part 441), ensuring full community integration and participant autonomy.

2. Regulatory and Oversight Agencies

Oversight of Adult Companion Services is divided between the state's umbrella social services agency and its specific programmatic divisions. Providers must interact with both the division managing their target population's waiver and the central Medicaid office.

The programmatic divisions handle initial certification, policy enforcement, and quality surveys, while the Medicaid office handles billing enrollment, claims processing, and financial audits.

• Umbrella Agency: Indiana Family and Social Services Administration (FSSA) oversees all Medicaid and social service programs in the state.
• Programmatic Division (Disabilities): Division of Disability and Rehabilitative Services (DDRS) / Bureau of Disabilities Services (BDS) certifies providers for the CIH and FSW waivers.
• Programmatic Division (Aging): Division of Aging (DA) oversees providers operating under the PathWays for Aging and Health and Wellness waivers.
• Medicaid Agency: Office of Medicaid Policy and Planning (OMPP) administers the Indiana Health Coverage Programs (IHCP) and manages federal Medicaid funding.
• System Portal: IHCP CoreMMIS serves as the central Medicaid management information system for provider enrollment and claims processing.

3. Gatekeeping Prerequisites: Who Can Even Apply

Indiana imposes strict structural preconditions on HCBS provider enrollment. Applicants must clear these administrative and regulatory hurdles before an application will even be reviewed by the state.

The most critical current barrier is a state-mandated moratorium on new HCBS waiver provider enrollments, which blocks new market entrants entirely for the duration of the order.

• Enrollment Moratorium: A 6-month HCBS Waiver Provider Enrollment Moratorium effective August 1, 2026, blocks new applications for specified services under PathWays, Health and Wellness, CIH, TBI, and FSW waivers.
• IHCP CoreMMIS Prerequisite: Per the federal 21st Century Cures Act, providers must be fully approved and active in IHCP CoreMMIS before attempting to credential with any Indiana Medicaid Managed Care Organization (MCO).
• Business Registration: Applicants must possess a valid Certificate of Incorporation or Certificate of Authority from the Indiana Secretary of State.
• Tax Identification: The agency must have an established Employer Identification Number (EIN) that exactly matches the business name on Line 2 of the submitted W-9 form.
• Physical Location Mandate: The agency must maintain a physical business address in Indiana; post office boxes and UPS stores are strictly prohibited for the service location address.

4. Licensure and Certification Requirements

Indiana does not issue a distinct facility or agency license for Adult Companion Services. Instead, providers must obtain HCBS Waiver Provider Certification directly from the FSSA by demonstrating compliance with the Indiana Administrative Code (IAC).

The specific certification standards depend on which waiver the provider intends to bill. Providers must submit comprehensive operational policies, proof of insurance, and financial documentation to pass a state readiness review.

• DDRS Certification: Approval is required under 460 IAC 6 for providers serving individuals with intellectual or developmental disabilities.
• Division of Aging Certification: Approval is required under 455 IAC 2 for providers serving the aged and disabled populations.
• Insurance Mandate: Providers must maintain and submit proof of general liability and professional liability insurance per 460 IAC 6-12-1 and 460 IAC 6-12-2.
• Financial Status: Applicants must submit documentation proving financial stability and adequate operating capital per 460 IAC 6-11-1 to 460 IAC 6-11-3.
• HCBS Settings Compliance: Providers must pass a programmatic readiness review confirming their service delivery model complies with federal HCBS Settings Rule requirements.

5. Medicaid Provider Enrollment

Once FSSA programmatic certification is obtained, agencies must enroll as billing providers through the IHCP Provider Healthcare Portal. This step connects the agency's state certification to the federal Medicaid payment system.

Enrollment requires submitting the state approval letters, paying federal application fees, and ensuring all corporate data matches federal tax records exactly.

• Enrollment Portal: Applications must be submitted electronically through the IHCP Provider Healthcare Portal accessed via CoreMMIS.
• Provider Type and Specialty: Applicants must select the specific HCBS Waiver Provider Type and Specialty codes that match their FSSA certification.
• Application Fee: Subject to the federal Medicaid institutional provider application fee (approximately $709, updated annually) unless waived or already paid to Medicare.
• Required Form: A W-9 form signed within the last six months must be uploaded with the application.
• Revalidation: Providers must complete the revalidation process every 5 years per 42 CFR 455.414 to maintain active billing status.

6. Staffing, Training and Background Checks

Direct support professionals (DSPs) providing companion services must meet strict state-mandated background, health, and training criteria before rendering services to vulnerable adults.

Agencies are responsible for maintaining continuous proof of these qualifications in their personnel files, as they are a primary focus during state audits.

• Criminal History: Mandatory state and national background checks must be completed for all direct care staff prior to employment per 460 IAC 6-10-5.
• Age Requirement: Direct care staff providing companion services must generally be at least 18 years of age.
• Basic Certifications: All direct care staff must hold current, hands-on CPR and First Aid certifications.
• Competency Training: Staff must complete FSSA-approved direct care training, covering incident reporting, participant rights, and person-centered planning.
• Health Screening: Staff must pass a tuberculosis (TB) screening prior to initial client contact and follow state guidelines for ongoing screening.

7. Documentation, Policies and Records

Providers must maintain comprehensive operational policies and participant records. These documents prove that services were delivered exactly as authorized and that the agency is prepared for emergencies.

Failure to maintain these records to state standards will result in immediate recoupment of Medicaid funds during an OMPP or FSSA audit.

• Personnel Records: Agencies must maintain files verifying background checks, training certificates, and health screenings per 455 IAC 2.
• Service Plans: Providers must maintain a current copy of the participant's state-approved Person-Centered Service Plan (PCSP) or Notice of Action (NOA).
• Activity Logs: Staff must keep daily documentation of companion activities, including exact start/stop times, dates, and the participant's response to the service.
• Incident Reporting: Agencies must enforce written policies for reporting adverse events to the state's incident reporting system within 24 hours.
• Emergency Response: Providers must maintain documented emergency and disaster preparedness plans tailored to community-based activities.

8. Billing, Rates and Claims

Companion services are reimbursed either on a fee-for-service basis directly by the state or through negotiated rates with Managed Care Organizations (MCOs), depending on the specific waiver.

All services must be prior-authorized by the state or MCO before delivery, and claims must strictly align with the authorized units and daily service logs.

• Billing System: Fee-for-service claims are submitted through the IHCP Provider Healthcare Portal (CoreMMIS).
• Claim Format: Professional claims must be submitted using the CMS-1500 form or the electronic 837P format.
• Prior Authorization: Services cannot be billed unless they are prior-authorized and listed on the participant's approved service plan.
• Unit of Service: Companion services are typically billed in 15-minute increments using specific HCPCS codes (e.g., S5135) as defined by the current waiver fee schedule.
• MCO Contracting: For managed care waivers like PathWays for Aging, providers must negotiate rates and submit claims directly to contracted MCOs (e.g., Anthem, CareSource).

9. Approval Sequence and Timeline

The end-to-end process requires sequential approvals from the Secretary of State, FSSA programmatic divisions, and finally IHCP. Skipping steps or applying out of order will result in automatic rejections.

While the historical timeline was 3 to 6 months, the process is currently halted or severely delayed due to the August 2026 enrollment moratorium.

• Step 1: Business Formation: Register the business entity with the Indiana Secretary of State and obtain a federal EIN.
• Step 2: FSSA Application: Submit the waiver provider application, policies, and financial documents to BDS or DA for programmatic review.
• Step 3: Readiness Review: Pass the state's programmatic and HCBS settings readiness review to receive the certification letter.
• Step 4: IHCP Enrollment: Submit the Medicaid enrollment application and fee via the IHCP Provider Healthcare Portal.
• Step 5: MCO Credentialing: Apply to managed care networks only after the IHCP CoreMMIS approval is fully active.

10. Common Denials and Survey Findings

Applications and routine surveys frequently fail due to administrative errors, premature submissions, or failure to adhere to strict documentation rules.

Because the state uses automated cross-checks, even minor typographical errors between federal tax documents and state applications will trigger a denial.

• Premature MCO Application: Attempting to credential with an MCO before receiving an active IHCP Provider ID in CoreMMIS is the most common cause of delays.
• Address Errors: Using a PO Box or UPS store instead of a physical service location address on the IHCP application results in automatic rejection.
• Name Mismatches: The business name on the IHCP application failing to exactly match Line 2 of the submitted W-9 form.
• Missing Background Checks: Survey citations frequently occur when agencies fail to complete or document criminal history checks per 460 IAC 6-10-5 before a staff member's first shift.
• Inadequate Documentation: Failing to maintain daily service logs that align with the billed units and the participant's PCSP leads to immediate funds recoupment.

11. Key Contacts and Resources

Prospective providers must utilize official state portals and division contacts to access the most current manuals, bulletins, and application materials.

Because waiver rules and moratoriums change frequently, providers should regularly monitor the IHCP Bulletins page for critical updates.

• Medicaid Enrollment: IHCP Provider Healthcare Portal (accessed via in.gov/medicaid/providers).
• Programmatic Division (Disabilities): FSSA Division of Disability and Rehabilitative Services (DDRS) / Bureau of Disabilities Services (BDS).
• Programmatic Division (Aging): FSSA Division of Aging (DA).
• Policy Updates: IHCP Bulletins and Reference Modules webpage for the latest provider manuals and moratorium notices.
• MCO Contracting: CareSource, Anthem, and other state-contracted MCOs for PathWays for Aging credentialing and network enrollment.

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