Indiana - Personal Emergency Response System — Licensing, Medicaid Enrollment and Startup Requirements

Last reviewed: 2026-08-15

In Indiana, a Personal Emergency Response System (PERS) is an electronic device that enables individuals at high risk of falls or medical emergencies to secure help 24 hours a day. The service is covered under Indiana's Home- and Community-Based Services (HCBS) waivers, including the PathWays for Aging program, the Health & Wellness Waiver, and the Traumatic Brain Injury (TBI) Waiver, providing a critical safety net for participants who live alone or are alone for significant parts of the day.

The single biggest structural barrier to entry for a new PERS provider in Indiana is the bifurcated, sequential approval process combined with mandatory managed care contracting. Providers cannot simply enroll in Medicaid; they must first obtain HCBS Certification from the Office of Medicaid Policy and Planning (OMPP), then enroll in the Indiana Health Coverage Programs (IHCP) via CoreMMIS, and finally secure network contracts with Managed Care Entities (MCEs) like Anthem, Humana, or UnitedHealthcare to receive referrals for the senior population.

1. Service Definition and Scope

The PERS service in Indiana encompasses the installation, maintenance, and ongoing 24/7 monitoring of emergency communication equipment. The system connects a waiver participant to a continuously staffed response center that can triage emergencies and dispatch local first responders or designated family members.

The service is strictly limited to the emergency device and monitoring. It does not cover routine utility charges, standard telephone services, or systems that lack active, live medical monitoring.

• Covered Waivers: Indiana PathWays for Aging, Health & Wellness Waiver, and Traumatic Brain Injury (TBI) Waiver.
• Service Components: Initial equipment installation, monthly monitoring fee, and equipment maintenance or replacement.
• Device Types: Wearable pendants, wristbands, and base units connected via landline or cellular networks.
• Response Center Standards: Must operate 24 hours a day, 7 days a week, 365 days a year without interruption.
• Target Population: Waiver participants who live alone, or who are alone for significant parts of the day, and have no regular caregiver for extended periods.

2. Regulatory and Oversight Agencies

Indiana does not issue a distinct state health facility license for PERS providers through the Department of Health. Because it is a non-medical equipment service, oversight is managed entirely through Medicaid waiver certification and managed care credentialing.

Providers are approved through a certification process managed by the state's Medicaid authority, ensuring they meet the operational and safety standards required to serve vulnerable waiver populations.

• Certifying Agency: FSSA Office of Medicaid Policy and Planning (OMPP) issues the required HCBS Certification.
• Medicaid Authority: Indiana Health Coverage Programs (IHCP) manages the CoreMMIS provider enrollment system.
• Program Administration: FSSA Division of Aging (DA) oversees the aging waivers and the PathWays for Aging program.
• Managed Care Entities (MCEs): Anthem, Humana, and UnitedHealthcare manage the PathWays for Aging network and conduct ongoing provider oversight and credentialing.

3. Gatekeeping Prerequisites: Who Can Even Apply

Indiana does not impose a Certificate of Need (CON), moratorium, or closed-network RFP procurement for PERS providers. The market is open to any qualified business. However, there is a strict sequential prerequisite: an applicant cannot submit an IHCP Medicaid enrollment application without first obtaining an approved HCBS Certification.

Additionally, to serve the vast majority of the elderly population, providers face a network contracting gate. After state enrollment, they must successfully contract with the state's designated MCEs; standalone fee-for-service enrollment is insufficient for the PathWays for Aging program.

• Prior Approval Requirement: OMPP HCBS Certification must be fully approved and issued before an IHCP CoreMMIS enrollment application will be accepted.
• Business Registration: The entity must be registered and in active good standing with the Indiana Secretary of State.
• Network Contracting: Providers must successfully credential and contract with at least one of Indiana's designated MCEs (Anthem, Humana, UHC) to serve PathWays for Aging members.
• Atypical Provider Status: PERS providers must determine their NPI status; as an atypical service, they may enroll without an NPI unless they also bill for standard medical services.

4. Licensure and Certification Requirements

Because there is no specific state license for PERS, providers must complete the OMPP HCBS Certification process via the FSSA Provider Enrollment portal. This step verifies the agency's operational readiness, safety protocols, and business legitimacy.

The certification process is heavily document-driven. Providers must upload comprehensive operational manuals, proof of insurance, and organizational charts. FSSA strictly rejects applications containing blank documents or templates bearing another agency's name.

• Application Portal: Submissions must be made through the OMPP HCBS Certification Portal at omppproviders.fssa.in.gov.
• Required Policies: Must upload specific operational manuals, including emergency response protocols, participant grievance policies, and incident reporting procedures.
• Insurance Requirement: Proof of active commercial general liability insurance is required; quotes or templates are explicitly rejected.
• Document Accuracy: All uploaded policies must explicitly match the agency's legal name as registered with the state.
• Background Check Proof: Must submit evidence that the agency has a compliant background check process in place for all staff.

5. Medicaid Provider Enrollment

Once OMPP HCBS Certification is granted, the provider must enroll in the Indiana Health Coverage Programs (IHCP) using the Provider Healthcare Portal. This step establishes the provider's billing profile in the CoreMMIS system.

Per IHCP Matrix Version 11, missing documentation or name mismatches are the leading causes of application rejection. Every detail on the application must perfectly align with IRS and state records.

• Enrollment System: Applications are processed through the IHCP Provider Healthcare Portal at portal.indianamedicaid.com.
• Provider Type/Specialty: Must select the appropriate HCBS Waiver provider type and the specific PERS specialty code.
• W-9 Form: The business name on line 2 of the W-9 must exactly match the CoreMMIS application and Indiana Secretary of State records.
• EFT Authorization: Required for electronic funds transfer, accompanied by a voided check or bank verification letter.
• Application Fee: Must pay the standard IHCP provider enrollment application fee (if applicable to the assigned risk category) or provide proof of payment to Medicare or another state Medicaid program.

6. Staffing, Training and Background Checks

While PERS is primarily an equipment and monitoring service, any staff entering a participant's home for installation, as well as the response center operators, must meet strict state background and training standards.

Agencies must maintain a roster of all personnel and ensure continuous compliance with federal exclusion lists to prevent Medicaid fraud and abuse.

• Background Checks: National and state criminal history checks are required for all staff entering participant homes for installation or maintenance.
• OIG Exclusion: Mandatory monthly screening of all employees against the federal LEIE (List of Excluded Individuals/Entities).
• Response Center Training: Operators must be formally trained in emergency triage, dispatching local EMS, and contacting designated family responders.
• Installation Staff: Technicians must be trained on device setup, signal testing, and educating the waiver participant on how to properly use the system.

7. Documentation, Policies and Records

FSSA requires strict adherence to documentation standards to justify Medicaid reimbursement. Providers must maintain records of all installations, monthly tests, and emergency activations.

These records are subject to audit by OMPP, the Division of Aging, and the contracted MCEs. Failure to produce testing logs or incident reports can result in immediate recoupment of funds.

• Service Plans: Must maintain a copy of the participant's approved Plan of Care (POC) or Notice of Action (NOA) authorizing the PERS service.
• Testing Logs: Documentation of initial system testing upon installation and ongoing monthly signal tests to ensure connectivity.
• Incident Reporting: Must comply with FSSA incident reporting policies for any failure of the PERS equipment during an actual emergency.
• Record Retention: All Medicaid service, testing, and billing records must be retained for a minimum of seven years.

8. Billing, Rates and Claims

PERS is billed using specific HCPCS codes for the initial installation and the ongoing monthly monitoring. Under the PathWays for Aging program, claims are submitted directly to the participant's MCE rather than the state's fee-for-service system.

Providers must ensure that the service is explicitly authorized on the member's Plan of Care before rendering services, as retroactive authorizations are rarely granted.

• Billing Codes: Typically billed using S5160 (Emergency response system; installation and testing) and S5161 (Emergency response system; service fee, per month).
• Prior Authorization: Services must be explicitly listed and approved on the member's Plan of Care (POC) generated by the waiver case manager.
• Claim Submission (MCE): For PathWays for Aging members, claims are routed through the provider's clearinghouse to Anthem, Humana, or UHC.
• Claim Submission (FFS): For traditional fee-for-service waiver members, claims are submitted directly via the IHCP Provider Healthcare Portal.

9. Approval Sequence and Timeline

The end-to-end process from business formation to billing the first claim involves three distinct phases: OMPP Certification, IHCP Enrollment, and MCE Contracting.

Because these steps must be completed sequentially, new providers should plan for a multi-month lead time before they can actively accept referrals and generate revenue.

• Phase 1 (OMPP Certification): Takes 30 to 60 days for FSSA to review operational policies and issue the HCBS certification.
• Phase 2 (IHCP Enrollment): Takes 15 to 30 days for CoreMMIS processing once the application and OMPP certification are submitted.
• Phase 3 (MCE Credentialing): Takes 60 to 90 days to complete credentialing and contracting with the managed care plans.
• Total Timeline: Providers should expect a 4 to 6-month total lead time before they are fully active in the PathWays for Aging network.

10. Common Denials and Survey Findings

Applications are frequently delayed or denied due to preventable administrative errors rather than substantive disqualifications. FSSA and IHCP strictly enforce document matching rules.

During the OMPP certification phase, uploading generic templates or expired documents will cause the application to be immediately set to expire, requiring a complete resubmission.

• Name Mismatches: CoreMMIS rejections occur when the W-9 name does not perfectly match the application or Secretary of State records.
• Incomplete Policies: OMPP portal rejections for uploading blank documents, expired background checks, or policies containing another agency's name.
• Missing Signatures: W-9 or EFT forms lacking an original, wet or approved digital signature from an authorized representative.
• Premature Enrollment: Attempting to initiate an IHCP CoreMMIS application before the OMPP HCBS Certification is fully approved and issued.

11. Key Contacts and Resources

Providers must navigate multiple state portals and rely on specific FSSA divisions for guidance throughout the lifecycle of their enrollment.

Maintaining contact with regional provider relations consultants is highly recommended to resolve CoreMMIS application holds or billing issues.

• OMPP Certification Portal: omppproviders.fssa.in.gov (used for initial waiver certification and policy uploads).
• IHCP Provider Portal: portal.indianamedicaid.com (used for Medicaid enrollment, fee-for-service billing, and EFT setup).
• FSSA Division of Aging: Oversees waiver policy, service definitions, and the PathWays for Aging program.
• IHCP Provider Relations: Regional consultants available to assist with CoreMMIS enrollment questions and application tracking.

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