Indiana - Assisted Living Facility — Licensing, Medicaid Enrollment and Startup Requirements

Last reviewed: 2026-08-15

In Indiana, "Assisted Living" is not a distinct, standalone licensure category. To provide Medicaid-reimbursed assisted living services, a facility must be licensed as a Residential Care Facility (RCF) by the Indiana Department of Health (IDOH) and subsequently certified as a Home- and Community-Based Services (HCBS) provider by the Family and Social Services Administration (FSSA). Services are primarily funded through the PathWays for Aging program (which replaced the Aged and Disabled Waiver for individuals 60 and older) and the Traumatic Brain Injury (TBI) Waiver.

The single biggest structural barrier to entry in Indiana is the sequential dependency of physical licensure prior to Medicaid enrollment, coupled with strict compliance with the CMS HCBS Settings Final Rule. Providers cannot initiate FSSA Office of Medicaid Policy and Planning (OMPP) HCBS certification or Indiana Health Coverage Programs (IHCP) Medicaid enrollment until the IDOH RCF license is fully approved and issued. This means operators must carry the capital costs of a fully staffed, compliant, and licensed physical plant without Medicaid revenue during the lengthy initial licensing and certification phases.

1. Service Definition and Scope

Indiana defines the physical setting for assisted living under the Residential Care Facility (RCF) regulations found in 410 IAC 16.2-5. An RCF provides residential nursing care or administers medications prescribed by a physician. Unlicensed entities can register as a "Housing with Services Establishment," but they cannot provide direct nursing or medication administration without contracting a home health agency, nor can they bill Medicaid for assisted living waiver services.

Under Indiana Medicaid HCBS waivers, assisted living services provide an alternative to nursing facility care for individuals meeting a nursing facility level of care. The service includes personal care, homemaker services, chore services, attendant care, and medication oversight provided in a home-like environment.

• Licensure Category: Residential Care Facility (RCF) governed by 410 IAC 16.2-5.
• Service Scope: Includes room, meals, laundry, activities, housekeeping, assistance with activities of daily living (ADLs), medication administration, and residential nursing care.
• Housing with Services Registry: Unlicensed facilities providing only room, board, and limited ADL assistance must file a disclosure with the FSSA Division of Aging, but are ineligible for Medicaid Assisted Living enrollment.
• Medicaid Waiver Definition: Assisted living services under 1915(c) waivers require RCF licensure and provide 24-hour on-site response to meet scheduled and unpredictable resident needs.
• Physical Setting Requirements: To qualify for Medicaid reimbursement, facilities must offer units with a bedroom, a private bath, a substantial living area, and a kitchen or kitchenette.

2. Regulatory and Oversight Agencies

Oversight of assisted living in Indiana is bifurcated between health and safety regulation and Medicaid program administration. The Indiana Department of Health (IDOH) is the regulatory body responsible for the physical plant, life safety, and clinical care standards of Residential Care Facilities.

The Indiana Family and Social Services Administration (FSSA) manages the Medicaid side. Within FSSA, the Division of Aging (DA) oversees waiver policy, while the Office of Medicaid Policy and Planning (OMPP) handles HCBS provider certification. Gainwell Technologies operates the Indiana Health Coverage Programs (IHCP) portal for final Medicaid enrollment and claims.

• Indiana Department of Health (IDOH) Long Term Care Division: Licenses Residential Care Facilities and conducts initial and annual health and safety surveys.
• FSSA Division of Aging (DA): Manages the Housing with Services registry and oversees the PathWays for Aging and TBI waiver programs.
• FSSA Office of Medicaid Policy and Planning (OMPP): Processes HCBS provider certification applications through the OMPP Certification Portal.
• Indiana Health Coverage Programs (IHCP): Manages final Medicaid provider enrollment, issues Provider IDs, and processes claims via Gainwell Technologies.
• Indiana Professional Licensing Agency (IPLA): Issues licenses for Health Facility Administrators (HFAs) and Residential Care Administrators (RCAs).

3. Gatekeeping Prerequisites: Who Can Even Apply

Indiana does not require a Certificate of Need (CON) for Residential Care Facilities, nor are there closed enrollment windows, moratoria, or Request for Proposal (RFP) procurements required to become a Medicaid Assisted Living provider. The market is open to any qualified entity that can meet the physical and operational standards.

However, strict structural prerequisites exist before a Medicaid application is accepted. The facility must already possess an active IDOH RCF license, and the physical plant must pass federal HCBS Settings Final Rule scrutiny to prove it is community-based and not institutional. Facilities located on the grounds of, or immediately adjacent to, a public institution are presumed institutional and face heightened federal scrutiny.

• Certificate of Need (CON): None required; Indiana's CON program applies to comprehensive care (nursing homes), not Residential Care Facilities.
• Procurement/RFP: None; Indiana operates an open enrollment network for Medicaid HCBS waiver providers.
• Licensure Prerequisite: Applicants must possess an active, unencumbered IDOH Residential Care Facility license before initiating the OMPP HCBS certification process.
• HCBS Settings Final Rule: Facilities must demonstrate compliance with 42 CFR Part 441, ensuring residents have lockable doors, choice of roommates, and freedom to control their schedules and access food at any time.
• Administrator Licensure: The facility must employ an Administrator actively licensed by the Indiana State Board of Health Facility Administrators (IPLA).

4. Licensure and Certification Requirements

Obtaining an RCF license from IDOH requires a multi-step process beginning with architectural review and culminating in an on-site health and life safety survey. Facilities must submit detailed floor plans to the IDOH Health Care Engineering Program before construction or renovation begins.

Once the physical plant is ready, the provider submits the formal licensure application and undergoes a pre-occupancy inspection. The facility cannot admit residents requiring residential nursing care or medication administration until the license is officially issued.

• Application Form: Must submit State Form 51110 (Application for License to Operate a Health Facility) to the IDOH Long Term Care Division.
• Architectural Review: Must submit architectural plans and specifications to the IDOH Health Care Engineering Program for approval prior to construction.
• Disclosure Statement: Must file a Housing with Services Establishment disclosure form with the FSSA Division of Aging.
• Life Safety Code: The physical plant must pass an IDOH Life Safety Code inspection for residential board and care occupancies.
• Initial Health Survey: Must pass an on-site IDOH pre-occupancy survey verifying compliance with 410 IAC 16.2-5 standards.
• Licensure Fee: Must pay an annual licensure fee to IDOH based on the number of licensed beds.

5. Medicaid Provider Enrollment

Enrolling as a Medicaid Assisted Living provider in Indiana is a two-step process. First, the provider must obtain HCBS Certification through the FSSA OMPP Certification Portal. This step verifies the provider's RCF license, policies, and HCBS Settings Rule compliance.

Second, after receiving OMPP certification, the provider must complete the formal Medicaid enrollment application through the IHCP Provider Healthcare Portal. This step establishes the provider's billing profile in the state's MMIS.

• Step 1 (OMPP Certification): Submit the initial provider certification request, RCF license, and required operational policies through the OMPP Certification Portal.
• Step 2 (IHCP Enrollment): Complete the IHCP Provider Enrollment Application via the Gainwell-managed IHCP Provider Healthcare Portal.
• Provider Taxonomy: Enroll as Provider Type 32 (Waiver Provider) with Specialty 359 (Assisted Living).
• Application Fee: Must pay the federal Medicaid/Medicare institutional application fee (approximately $709 for 2024) unless already enrolled and paid via Medicare.
• NPI Requirement: Must obtain and link a Type 2 (Organizational) National Provider Identifier (NPI).
• EFT Enrollment: Must complete Electronic Funds Transfer (EFT) enrollment during the IHCP application process for direct deposit of claims.

6. Staffing, Training and Background Checks

Indiana RCF regulations mandate that staffing levels must be sufficient to meet the needs of the residents at all times. While specific direct-care-to-resident ratios are not strictly codified by a single number, the facility must have awake staff on duty 24 hours a day.

Medication administration is strictly regulated and must be performed by licensed nursing personnel or certified Qualified Medication Aides (QMAs). All staff must undergo rigorous background screening and health checks prior to resident contact.

• Administrator: Must employ a licensed Health Facility Administrator (HFA) or Residential Care Administrator (RCA).
• Nursing Staff: Medication administration must be performed by a Registered Nurse (RN), Licensed Practical Nurse (LPN), or Qualified Medication Aide (QMA).
• Direct Care Staff: Must receive orientation and ongoing in-service training on resident rights, infection control, fire safety, and emergency procedures.
• Background Checks: Must complete Indiana State Police limited criminal history checks for all employees prior to direct contact with residents.
• Health Screening: All staff must have a physical examination and tuberculosis (TB) screening upon hire and annually thereafter.
• First Aid/CPR: At least one staff member certified in first aid and CPR must be on duty at all times.

7. Documentation, Policies and Records

Providers must maintain comprehensive documentation to satisfy both IDOH licensure rules and OMPP HCBS certification standards. The OMPP Certification Portal requires the upload of specific, named policies that must exactly match the agency's legal name.

Resident records must be kept current, reflecting comprehensive assessments, individualized service plans, and clear documentation of all medications administered and services rendered.

• Resident Agreement: Must execute a written contract detailing services, fees, discharge criteria, and resident rights prior to admission.
• Service Plan: Must develop a personalized care plan based on a comprehensive assessment within 30 days of admission, updated at least semi-annually or upon significant change.
• Emergency Preparedness: Must maintain a disaster preparedness plan approved by local emergency management authorities.
• HCBS Compliance Policies: Must document policies ensuring resident rights, privacy, lockable doors, and freedom from coercion under 42 CFR Part 441.
• Incident Reporting: Must maintain policies for reporting adverse events (e.g., abuse, neglect, elopement) to the IDOH Incident Reporting System within 24 hours.
• Medication Records: Must maintain a Medication Administration Record (MAR) for every resident receiving medication assistance.

8. Billing, Rates and Claims

Medicaid reimbursement for assisted living in Indiana is billed on a per diem basis through the IHCP Provider Healthcare Portal. Rates are typically tiered based on the resident's assessed level of care needs, which are determined by the state's area agencies on aging or care management entities.

It is critical to note that Medicaid waiver funds cannot be used to pay for room and board. Residents are responsible for paying their own room and board costs using their personal income, such as Social Security or SSI.

• Billing Portal: Claims are submitted electronically through the IHCP Provider Healthcare Portal or via an approved EDI clearinghouse.
• Claim Format: Billed using the professional claim format (CMS-1500 or 837P electronic equivalent).
• Procedure Codes: Billed using specific HCPCS codes (e.g., T2031 for Assisted Living Waiver per diem) with appropriate modifiers designating the waiver program.
• Tiered Rates: Reimbursement is based on state-established tiered rates corresponding to the resident's acuity and care plan.
• Room and Board: Medicaid does not cover room and board; providers must collect this directly from the resident's income up to the state-mandated maximum.
• Prior Authorization: Services must be authorized on the resident's Notice of Action (NOA) and care plan before claims will pay.

9. Approval Sequence and Timeline

Becoming a Medicaid Assisted Living provider in Indiana is a lengthy process due to the requirement to build or acquire a facility, license it, and then certify it. The entire process from architectural review to Medicaid billing can take 12 to 24 months.

Providers must carefully sequence their applications, as OMPP will automatically reject HCBS certification applications if the IDOH RCF license is not already active and uploaded.

• Phase 1 (Architectural): Submit plans to IDOH Health Care Engineering; approval typically takes 30-90 days.
• Phase 2 (Licensure): Submit SF 51110, pass Life Safety and Initial Health surveys, and receive the RCF license (typically 3-6 months after construction completion).
• Phase 3 (OMPP Certification): Submit policies and the active RCF license to the OMPP Certification Portal; review takes 30-60 days.
• Phase 4 (IHCP Enrollment): Submit the IHCP application via the Gainwell portal; processing takes 30-45 days.
• Phase 5 (Contracting): Execute agreements with care management entities (e.g., Area Agencies on Aging) to begin receiving resident referrals.

10. Common Denials and Survey Findings

Applications are frequently delayed or denied at the OMPP Certification stage due to administrative errors, such as uploading blank documents, expired background checks, or policies that contain a different agency's name (often a result of copying templates).

During IDOH surveys, facilities are most commonly cited for medication administration errors, failure to update resident service plans following a change in condition, and physical plant/life safety code violations.

• OMPP Rejections: Uploading blank documents, expired background checks, or policies with a different agency's name in the OMPP Portal.
• Medication Errors: IDOH citations for improper medication storage, administration by uncertified staff, or lack of QMA/Nurse oversight.
• HCBS Settings Failures: Denials for institutional characteristics, such as lack of private locks, restricted visiting hours, or forced meal times.
• Incomplete Service Plans: Citations for failing to update resident care plans when a significant change in medical or cognitive condition occurs.
• Life Safety Code: Delays in initial licensure due to failing fire alarm, sprinkler, or egress inspections during the IDOH engineering survey.
• Background Check Gaps: Citations for allowing staff to begin direct resident care before the Indiana State Police limited criminal history check is returned.

11. Key Contacts and Resources

Providers must interact with multiple state portals and divisions. The IDOH Long Term Care Division is the primary contact for physical licensure, while the FSSA OMPP handles waiver certification.

Familiarity with the Indiana Administrative Code (IAC) and the IHCP Provider Reference Modules is essential for maintaining compliance and ensuring accurate billing.

• IDOH Long Term Care Division: Oversees RCF licensing, engineering reviews, and health surveys (in.gov/health/ltc).
• FSSA OMPP Certification Portal: The mandatory gateway for HCBS waiver certification (omppproviders.fssa.in.gov).
• IHCP Provider Healthcare Portal: Managed by Gainwell Technologies for Medicaid enrollment and claims (portal.indianamedicaid.com).
• Indiana Administrative Code: 410 IAC 16.2-5 contains the comprehensive operational standards for Residential Care Facilities.
• FSSA Division of Aging: Manages the Housing with Services registry and waiver policy (in.gov/fssa/da).
• Indiana Professional Licensing Agency (IPLA): Processes licenses for Health Facility Administrators (in.gov/pla).

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