Indiana - Personal Assistance Services — Licensing, Medicaid Enrollment and Startup Requirements

Last reviewed: 2026-08-16

In Indiana, Personal Assistance Services are formally delivered under Medicaid Home- and Community-Based Services (HCBS) waivers as Attendant Care or Personal Care Services. These services provide essential, hands-on assistance with Activities of Daily Living (ADLs) such as bathing, dressing, transferring, and toileting, enabling aged individuals and those with disabilities to remain safely in their own homes rather than entering institutional care.

The single biggest structural barrier to entry for this service in Indiana is the state's strict, multi-tiered gatekeeping sequence combined with managed care network restrictions. An applicant cannot simply enroll in Medicaid; they must first secure a Personal Services Agency (PSA) license from the Indiana Department of Health (IDOH), then obtain HCBS Certification from the Family and Social Services Administration (FSSA), and finally secure network contracts with Managed Care Entities (MCEs) under the PathWays for Aging program. Furthermore, FSSA periodically imposes strict enrollment moratoria on new Attendant Care providers to combat fraud, which completely blocks new applications during the moratorium window.

1. Service Definition and Scope

In Indiana, hands-on personal assistance is formally categorized as Attendant Care Services or Personal Care Services under the state's HCBS waivers. It encompasses direct, physical assistance with Activities of Daily Living (ADLs) delivered in the participant's private residence or community setting.

Services must be strictly authorized in the participant's state-approved Individualized Support Plan (ISP) or Service Plan. Providers are strictly prohibited from performing skilled nursing tasks, wound care, or medication administration unless they are dually licensed as a Home Health Agency and operating under specific nursing delegation rules.

• Service Nomenclature: Officially billed as Attendant Care Services or Personal Care Services depending on the specific FSSA waiver.
• Target Populations: Serves older adults (PathWays for Aging), individuals with physical disabilities (Health & Wellness Waiver), and those with intellectual/developmental disabilities (FSW/CIH waivers).
• Included ADLs: Hands-on assistance with bathing, grooming, dressing, toileting, transferring, and mobility.
• Included IADLs: Light housekeeping, meal preparation, and medication reminders, provided they are incidental to the primary personal care tasks.
• Excluded Tasks: Skilled nursing care, sterile wound care, and direct medication administration are excluded from standard Attendant Care.
• Setting Limitations: Services must be delivered in the participant's home or community, fully compliant with the CMS HCBS Settings Rule.

2. Regulatory and Oversight Agencies

Oversight of Attendant Care in Indiana is divided between health and safety licensure and Medicaid waiver administration. The Indiana Department of Health (IDOH) handles the baseline agency licensure required to operate legally in the state.

The Family and Social Services Administration (FSSA) manages the Medicaid waivers. Within FSSA, the Office of Medicaid Policy and Planning (OMPP) oversees the PathWays and Health & Wellness waivers, while the Division of Disability and Rehabilitative Services (DDRS) oversees developmental disability waivers.

• Indiana Department of Health (IDOH): Issues the mandatory Personal Services Agency (PSA) license required to provide non-medical care (https://www.in.gov/health/).
• FSSA Office of Medicaid Policy and Planning (OMPP): Certifies HCBS providers for PathWays, Health & Wellness, and TBI waivers (https://www.in.gov/fssa/ompp/).
• FSSA Division of Disability and Rehabilitative Services (DDRS): Certifies providers for the Family Supports Waiver (FSW) and Community Integration and Habilitation (CIH) waiver (https://www.in.gov/fssa/ddrs/).
• Indiana Health Coverage Programs (IHCP): Manages the actual Medicaid provider enrollment, MMIS, and fee-for-service billing (https://www.in.gov/medicaid/providers/).
• Managed Care Entities (MCEs): Anthem, Humana, and UnitedHealthcare administer the PathWays for Aging program and manage provider networks (https://www.in.gov/medicaid/members/programs/pathways-for-aging/).

3. Gatekeeping Prerequisites: Who Can Even Apply

Indiana imposes strict sequential prerequisites for Attendant Care providers. You cannot submit a Medicaid enrollment application until you have successfully navigated state licensure and FSSA certification.

The most critical barriers include FSSA's utilization of enrollment moratoria to curb fraud in the Attendant Care space, and mandatory MCE contracting for the PathWays program, which operates as a closed network if an MCE determines its regional network adequacy is already met.

• IDOH Licensure Prerequisite: Applicants must hold an active Personal Services Agency (PSA) or Home Health Agency (HHA) license from IDOH before seeking Medicaid certification.
• FSSA Moratoria: Applicants must verify that FSSA has not placed a temporary moratorium on new Attendant Care provider enrollments, a tool the state uses to audit existing networks and prevent fraud.
• OMPP HCBS Certification: Required prior to IHCP enrollment for PathWays, H&W, and TBI waivers; obtained via the OMPP HCBS Certification Portal.
• DDRS BDDS Certification: Required prior to IHCP enrollment for providers targeting the FSW and CIH developmental disability waivers.
• MCE Network Contracting: For the PathWays for Aging program, providers must secure contracts with Anthem, Humana, or UHC; MCEs have the authority to deny contracts if their networks are full.
• Business Registration: The entity must be registered with the Indiana Secretary of State and possess a Type 2 (Organizational) National Provider Identifier (NPI).

4. Licensure and Certification Requirements

To operate legally in Indiana, non-medical personal care providers must obtain a Personal Services Agency (PSA) license from IDOH under Indiana Code IC 16-27-4. This establishes the baseline health and safety standards for the agency.

After obtaining the PSA license, the agency must apply for HCBS Certification through the FSSA OMPP or DDRS portals. This requires submitting extensive policy manuals, organizational charts, and proof of compliance with the federal HCBS Settings Rule.

• PSA License Application: Submitted to the Indiana Department of Health with a $250 initial application fee.
• Manager Qualifications: The agency must designate a manager who meets IDOH qualifications, typically requiring documented experience in health care or human services.
• OMPP Certification Portal: Providers must upload operational policies, organizational charts, and insurance certificates for OMPP review to receive their HCBS certification letter.
• Insurance Mandates: Agencies must maintain general liability, professional liability, and worker's compensation insurance, submitting active certificates (not just quotes) to FSSA.
• HCBS Settings Rule Compliance: Providers must submit documentation proving their service delivery model integrates participants into the community and respects their autonomy and privacy.
• Financial Solvency: Agencies may be required to demonstrate the financial capacity to operate for at least 90 days without Medicaid revenue during the initial startup phase.

5. Medicaid Provider Enrollment

Once IDOH licensed and FSSA certified, providers apply to the Indiana Health Coverage Programs (IHCP) via the IHCP Provider Healthcare Portal, which is managed by Gainwell Technologies.

Attendant Care providers enroll under specific provider types and specialties. Because personal care is considered a high-risk service for fraud, waste, and abuse, the enrollment process requires an application fee and fingerprint-based background checks for owners.

• IHCP Provider Healthcare Portal: The mandatory online system for submitting the Medicaid enrollment application (https://portal.indianamedicaid.com/).
• Provider Type and Specialty: Agencies typically enroll as Provider Type 32 (Waiver Provider) with specialties corresponding to Attendant Care.
• Application Fee: Must pay the CMS-mandated institutional provider application fee (approximately $709 for 2024/2025) unless waived by concurrent Medicare enrollment.
• Risk Level Screening: HCBS personal care providers are categorized as High Risk, requiring fingerprinting and criminal background checks for all owners with a 5% or greater interest.
• Required Attachments: Applications must include a W-9, the FSSA HCBS Certification letter, the IDOH PSA License, and NPI confirmation.
• Revalidation: Providers must revalidate their IHCP enrollment every 3 to 5 years, depending on their assigned risk level.

6. Staffing, Training and Background Checks

Indiana mandates strict personnel standards for Attendant Care staff under both IDOH PSA rules and FSSA waiver requirements. Direct care workers must be thoroughly vetted and proven competent to perform ADLs safely.

Agencies must maintain comprehensive personnel files proving that all background checks, health screenings, and training were completed prior to the employee's first independent shift with a participant.

• Criminal Background Checks: Must complete an Indiana State Police limited criminal history check and a National Sex Offender Registry check before hire.
• Registry Verifications: Agencies must check the OIG List of Excluded Individuals/Entities (LEIE) and the Indiana Nurse Aide Registry prior to employment.
• Health Screening: Direct care staff must have a negative TB (tuberculosis) test or chest X-ray prior to any direct client contact.
• Initial Training: Staff must complete agency-specific orientation, CPR/First Aid certification, and training on participant rights and abuse/neglect reporting.
• Competency Evaluation: A registered nurse (RN) or qualified agency manager must evaluate and document the aide's competency in specific ADL tasks before they provide care independently.
• Ongoing Training: A minimum of 12 hours of annual in-service training is required for all personal care staff.

7. Documentation, Policies and Records

FSSA and IDOH require exhaustive documentation to justify billing and ensure participant safety. Blank templates or generic policies are frequently rejected during the OMPP certification process.

Service notes must clearly link the tasks performed to the participant's approved Service Plan, including exact start and stop times, and must be captured electronically.

• Electronic Visit Verification (EVV): Indiana mandates EVV for all personal care services; providers must use the state-sponsored Sandata system or an approved alternate EVV vendor.
• Service Delivery Records: Must document the date of service, exact start/stop times, specific ADLs performed, and the staff member's signature.
• Incident Reporting: Policies must dictate the reporting of adverse events (abuse, neglect, exploitation) to FSSA within 24 hours via the state's incident reporting system.
• Participant Service Plan: A copy of the state-approved Individualized Support Plan (ISP) or Notice of Action (NOA) must be maintained in the client's home and the agency file.
• Emergency Preparedness: Agencies must have documented, participant-specific emergency response plans for natural disasters or medical emergencies.
• Record Retention: All clinical, personnel, and billing records must be retained for a minimum of seven years.

8. Billing, Rates and Claims

Billing for Attendant Care is processed through the IHCP CoreMMIS system for fee-for-service waivers, or directly to the respective MCEs' clearinghouses for the PathWays for Aging program.

Rates are strictly established by FSSA. Providers must accept the Medicaid rate as payment in full and cannot balance-bill Medicaid participants for any difference between the agency's private pay rate and the Medicaid allowable rate.

• Billing System: Fee-for-service claims are submitted via the IHCP Provider Healthcare Portal (CoreMMIS); managed care claims go through Anthem, Humana, or UHC.
• Claim Format: Services are billed using the professional CMS-1500 claim form or the electronic 837P format.
• Procedure Codes: Typically billed using HCPCS codes such as S5125 (Attendant Care Services, per 15 minutes) with appropriate waiver modifiers.
• EVV Requirement: Claims will automatically deny if they are not matched with corresponding, compliant EVV data in the Sandata aggregator.
• Prior Authorization: All services must be prior-authorized and listed on the participant's Notice of Action (NOA) before billing can occur.
• Rate Structure: Reimbursed on a 15-minute unit basis, with rates published on the FSSA OMPP fee schedule (subject to legislative updates).

9. Approval Sequence and Timeline

Becoming a fully operational Medicaid Attendant Care provider in Indiana is a lengthy, multi-step process that typically takes 6 to 12 months from start to finish.

Delays are incredibly common if policy manuals are incomplete during the OMPP certification phase, if fingerprinting is delayed, or if MCE contracting is backlogged.

• Step 1: Business Formation & NPI (1-2 weeks) - Register with the Indiana Secretary of State and obtain a Type 2 NPI.
• Step 2: IDOH PSA Licensure (60-90 days) - Submit the application, pay the fee, and pass the initial IDOH desk review.
• Step 3: FSSA HCBS Certification (60-120 days) - Submit operational policies to the OMPP or DDRS portal and undergo readiness review.
• Step 4: IHCP Enrollment (30-60 days) - Submit the application via the IHCP Portal, complete owner fingerprinting, and pay the application fee.
• Step 5: MCE Contracting (90-120 days) - Apply for network participation and credentialing with Anthem, Humana, and UHC for the PathWays program.
• Step 6: EVV Integration (2-4 weeks) - Set up the Sandata or alternate EVV system and complete mandatory state training.

10. Common Denials and Survey Findings

Applications are frequently rejected during the OMPP certification stage due to generic or incomplete policy manuals. FSSA explicitly warns against uploading blank templates or policies containing another agency's name.

Post-enrollment, IDOH and FSSA conduct surveys where documentation failures—especially regarding EVV compliance and background checks—lead to severe citations or financial recoupment.

• Plagiarized Policies: OMPP rejects applications if operational manuals contain a different agency's name or are clearly unedited, generic templates.
• Missing EVV Data: Claims are denied or funds recouped post-payment due to missing or mismatched Electronic Visit Verification records.
• Background Check Gaps: Citations are issued when staff begin working before the Indiana State Police or LEIE checks are fully completed and filed.
• Expired Documents: Certification is denied due to expired liability insurance quotes or outdated background checks submitted in the portal.
• Service Plan Deviations: Recoupment of funds occurs when billed hours exceed the authorized units on the participant's Notice of Action (NOA).
• Inadequate Competency Docs: Surveyors cite agencies for failing to have an RN or qualified manager sign off on a direct care worker's ADL competency prior to independent work.

11. Key Contacts and Resources

Providers must navigate multiple state portals and agency websites to maintain compliance. Bookmark these essential Indiana-specific resources for licensure, certification, and enrollment.

For direct assistance, providers should contact their regional IHCP Provider Relations consultant or the specific FSSA division handling their waiver.

• Indiana Department of Health (IDOH) PSA Licensing: https://www.in.gov/health/
• FSSA OMPP HCBS Certification Portal: https://omppproviders.fssa.in.gov/ProviderEnrollmentApplication/s/
• IHCP Provider Healthcare Portal (Gainwell): https://portal.indianamedicaid.com/
• FSSA Division of Disability and Rehabilitative Services (DDRS): https://www.in.gov/fssa/ddrs/
• Indiana Medicaid Provider Enrollment Info: https://www.in.gov/medicaid/providers/provider-enrollment/
• PathWays for Aging MCE - Anthem: https://providers.anthem.com/indiana-provider/patient-care/pathways-aging
• PathWays for Aging MCE - Humana: https://www.humana.com/provider/medical-resources/indiana-medicaid

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