Indiana - Skilled Nursing Services — Licensing, Medicaid Enrollment and Startup Requirements

Last reviewed: 2026-08-16

In Indiana, Skilled Nursing Services delivered in the home under physician orders—including assessments, medication administration, and skilled treatments—are governed under the Home Health Agency (HHA) framework. To provide these services to Medicaid Home- and Community-Based Services (HCBS) waiver participants, an entity must be licensed as an HHA by the Indiana Department of Health (IDOH) and subsequently enroll in the Indiana Health Coverage Programs (IHCP) [Home Health Services in Indiana - Waiver Consulting Group](https://help.waivergroup.com/en_US/guide-to-becoming-a-home-health-service-provider-in-indiana).

The single biggest structural barrier to entry for this service in Indiana is the mandatory IDOH Home Health Agency licensure and the required initial state operational survey. While Indiana does not require a Certificate of Need (CON) for home health providers, an agency cannot even apply for Medicaid HCBS waiver certification or IHCP enrollment for skilled nursing until it has successfully secured its state license and passed the IDOH on-site survey [Health: Consumer Services and Healthcare Regulation: Home Health Agency (HHA) Licensing and Certification Program](https://www.in.gov/health/cshcr/acute-and-continuing-care/home-health-agency-hha-licensing-and-certification-program).

1. Service Definition and Scope

Skilled Nursing Services under Indiana Medicaid HCBS waivers provide complex medical care by licensed nurses in a participant's home. These services are designed to prevent institutionalization and must be integrated into the participant's person-centered Service Plan.

Because Indiana does not have a standalone "Skilled Nursing" provider license for agencies, these services are delivered by licensed Home Health Agencies. The services require a physician's order and are strictly limited to clinical needs that exceed the scope of standard personal care or home health aide services.

• Service Scope: Includes comprehensive assessment, medication administration, wound care, tube feedings, and other skilled treatments.
• Provider Type: Must be a licensed Home Health Agency (HHA) in the state of Indiana.
• Applicable Waivers: Indiana PathWays for Aging, Health & Wellness Waiver, Traumatic Brain Injury (TBI) Waiver, and Division of Disability and Rehabilitative Services (DDRS) waivers.
• Prescription Requirement: Services must be explicitly ordered by a licensed physician, nurse practitioner, or physician assistant.
• Supervision: Licensed Practical Nurses (LPNs) must be supervised by a Registered Nurse (RN) in accordance with 410 IAC 17.

2. Regulatory and Oversight Agencies

Oversight of skilled nursing providers in Indiana is bifurcated. The state health department handles clinical licensure and safety surveys, while the social services administration manages waiver certification and Medicaid funding.

Providers must interact with multiple portals, including the state's HCBS certification portal and the primary Medicaid MMIS portal managed by Gainwell Technologies.

• Licensing Agency: Indiana Department of Health (IDOH) Acute and Continuing Care (https://www.in.gov/health/cshcr/acute-and-continuing-care/home-health-agency-hha-licensing-and-certification-program)
• Medicaid Authority: Indiana Family and Social Services Administration (FSSA) Office of Medicaid Policy and Planning (OMPP) (https://www.in.gov/medicaid/providers/)
• Waiver Certification (Aging/Physical Disabilities): FSSA HCBS Provider Portal (https://omppproviders.fssa.in.gov/ProviderEnrollmentApplication/s/)
• Waiver Certification (Intellectual/Developmental Disabilities): FSSA Division of Disability and Rehabilitative Services (DDRS) (https://www.in.gov/fssa/ddrs/developmental-disability-services/developmental-disabilities/)
• Medicaid Enrollment Portal: IHCP Provider Healthcare Portal (https://portal.indianamedicaid.com/hcp/provider/Home/ProviderEnrollment/tabid/477/Default.aspx)

3. Gatekeeping Prerequisites: Who Can Even Apply

Indiana operates an open enrollment model for Home Health Agencies and Medicaid HCBS providers. There is genuinely no Certificate of Need (CON), Facility Need Review (FNR), or county-level sponsorship required to apply for an HHA license or Medicaid enrollment in Indiana.

The primary gatekeeping mechanism is sequential: an applicant is structurally blocked from applying for Medicaid HCBS waiver certification until they have fully obtained their IDOH Home Health Agency license. There are no closed networks or RFP procurement windows blocking initial licensure.

• Certificate of Need (CON): None exists; Indiana does not require a CON or Facility Need Review for Home Health Agencies.
• Network Procurement: None; Indiana utilizes open enrollment for IHCP Medicaid providers without RFP or moratorium restrictions.
• Licensure Prerequisite: Must obtain an IDOH Home Health Agency license before any application for Medicaid HCBS waiver enrollment for skilled nursing is accepted.
• Business Registration: Must register the exact legal entity and any "Doing Business As" (DBA) names with the Indiana Secretary of State.
• NPI Requirement: Must obtain a Type 2 National Provider Identifier (NPI) prior to submitting the Medicaid enrollment application.

4. Licensure and Certification Requirements

To provide skilled nursing, the agency must be licensed as a Home Health Agency under Indiana Administrative Code 410 IAC 17. This requires submitting a formal application, paying a fee, and passing an initial state survey.

Agencies may choose to undergo a state-conducted survey by IDOH or utilize a CMS-approved accreditation organization (such as CHAP or ACHC) to meet the survey requirements for licensure and concurrent Medicare/Medicaid certification.

• Application Form: State Form 4008 (Application for License to Operate a Home Health Agency).
• Licensure Fee: $250.00 submitted to the Indiana Department of Health.
• Rule Citation: 410 IAC 17 (Home Health Agencies).
• Initial Survey: IDOH conducts a pre-licensure or initial operational survey to verify compliance with state health and safety standards.
• Accreditation Option: Agencies may use a CMS-approved accreditation organization for concurrent Medicare/Medicaid certification surveys in lieu of the standard state survey.

5. Medicaid Provider Enrollment

After obtaining the IDOH license, providers must enroll in the Indiana Health Coverage Programs (IHCP). For HCBS waivers, this involves a two-step process: waiver certification through the FSSA portal and IHCP enrollment via the Provider Healthcare Portal.

Because Home Health Agencies are considered high-risk providers under federal Medicaid rules, all owners with a 5% or greater interest must undergo fingerprint-based criminal background checks during the enrollment process.

• Waiver Certification: Submit application via the FSSA HCBS Provider Enrollment Portal for PathWays, Health & Wellness, and TBI waivers.
• IHCP Enrollment Portal: Submit the IHCP Provider Enrollment Application via the IHCP Provider Healthcare Portal.
• Provider Type: Enroll as Provider Type 12 (Home Health Agency) or Provider Type 32 (Waiver Provider) depending on the specific billing setup and waiver.
• Application Fee: Must pay the federal/state Medicaid provider enrollment application fee (or provide proof of payment to Medicare).
• Risk Screening: Subject to high-risk screening requirements, including fingerprint-based criminal background checks for owners with 5% or more interest.

6. Staffing, Training and Background Checks

Staff delivering skilled nursing must hold active Indiana nursing licenses. Agencies must maintain strict personnel files verifying credentials, background checks, and ongoing training.

Indiana mandates specific criminal history checks and health screenings for all direct care staff before they can provide services in a waiver participant's home.

• RN Qualifications: Must hold an active, unencumbered Registered Nurse license from the Indiana State Board of Nursing.
• LPN Qualifications: Must hold an active Licensed Practical Nurse license and practice under the direct supervision of an RN.
• Background Checks: Must complete expanded criminal history checks via the Indiana State Police per 460 IAC 6-10-5 and IDOH rules.
• Health Screening: Staff must have TB testing and health clearances prior to patient contact.
• Administrator: Must designate a Home Health Administrator meeting 410 IAC 17 qualifications to oversee daily operations.

7. Documentation, Policies and Records

Providers must maintain comprehensive clinical and administrative records. The Plan of Care (POC) is the central document dictating the frequency and scope of skilled nursing services.

All skilled nursing interventions must be explicitly ordered by a physician, and clinical notes must reflect the exact services authorized in the FSSA waiver Service Plan.

• Physician Orders: All skilled nursing services must be explicitly ordered by a physician and updated at least every 60 days.
• Plan of Care (POC): Must align with the FSSA waiver person-centered Service Plan and detail specific nursing interventions.
• Clinical Notes: Nurses must document each visit, including assessment findings, interventions performed, and patient response.
• Policy Manual: Must maintain an IDOH-approved policy manual covering infection control, emergency preparedness, and patient rights.
• Record Retention: Clinical records must be retained for at least seven years post-discharge.

8. Billing, Rates and Claims

Skilled nursing services are billed to IHCP or the contracted Managed Care Entity (MCE) for programs like PathWays for Aging. Rates are established by FSSA and billed in specific time increments.

Indiana requires the use of Electronic Visit Verification (EVV) for home health services, meaning all nursing visits must be electronically logged to verify the date, time, and location of service delivery.

• Billing System: Claims are submitted via the IHCP Provider Healthcare Portal (CoreMMIS) or the respective MCE portal.
• Billing Codes: Typically billed using HCPCS codes (e.g., T1002 for RN services, T1003 for LPN services) with appropriate waiver modifiers.
• Prior Authorization: Services must be prior-authorized and listed on the participant's Notice of Action (NOA) or Service Plan.
• Managed Care Contracting: For the PathWays for Aging waiver, providers must contract and credential with the participant's selected MCE (e.g., Anthem, CareSource, Humana, UHC).
• EVV Requirement: Electronic Visit Verification (EVV) is mandatory for in-home personal care and home health services in Indiana.

9. Approval Sequence and Timeline

The end-to-end process from business formation to billing Medicaid can take 6 to 12 months. This timeline is heavily dependent on IDOH survey scheduling and MCE credentialing timeframes.

Providers cannot back-date their Medicaid enrollment prior to the effective date of their IDOH Home Health Agency license and their approved IHCP network effective date.

• Step 1: Business registration and NPI acquisition (1-2 weeks).
• Step 2: Submit State Form 4008 and $250 fee to IDOH (30-60 days for document review).
• Step 3: IDOH Initial Survey (timeline varies, often 3-6 months depending on state backlog).
• Step 4: FSSA HCBS Waiver Certification via the HCBS portal (30-60 days).
• Step 5: IHCP Medicaid Enrollment via Provider Healthcare Portal (30-45 days).
• Step 6: MCE Credentialing and Contracting for PathWays for Aging (90-120 days).

10. Common Denials and Survey Findings

Applications and surveys are frequently delayed due to incomplete policies or failure to adhere to strict clinical documentation standards.

State surveyors and Medicaid auditors closely scrutinize physician orders and RN supervisory visits; deficiencies in these areas are the most common reasons for citations or claim recoupments.

• Application Denial: Failure to register the exact "Doing Business As" (DBA) name with the Indiana Secretary of State.
• Survey Deficiency: Incomplete or missing physician signatures on the 60-day Plan of Care updates.
• Survey Deficiency: Lack of documented RN supervisory visits for LPNs and Home Health Aides.
• Enrollment Rejection: Owners failing to complete the required fingerprint-based background checks within the 30-day window.
• Claim Denial: Billing for services before the official IHCP network effective date or without an active prior authorization on the NOA.

11. Key Contacts and Resources

Essential links and contacts for navigating the licensure and enrollment process in Indiana.

Providers should bookmark these official state portals and reference materials to ensure compliance with all IDOH and FSSA regulations.

• IDOH Home Health Licensing: https://www.in.gov/health/cshcr/acute-and-continuing-care/home-health-agency-hha-licensing-and-certification-program
• FSSA HCBS Provider Portal: https://omppproviders.fssa.in.gov/ProviderEnrollmentApplication/s/
• IHCP Provider Healthcare Portal: https://portal.indianamedicaid.com/hcp/provider/Home/ProviderEnrollment/tabid/477/Default.aspx
• IHCP Provider Reference Materials: https://www.in.gov/medicaid/providers/provider-references/provider-reference-materials/
• CareSource Indiana (MCE Example): https://www.caresource.com/in/providers/education/become-caresource-provider/medicaid/

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