Kentucky - Adult Companion Services — Licensing, Medicaid Enrollment and Startup Requirements
Last reviewed: 2026-09-10
Kentucky's Department for Medicaid Services (DMS) does not enroll providers under a distinct "Adult Companion Services" category, instead funding non-medical supervision and socialization through Home and Community Support Services (HCSS) under the Home and Community Based (HCB) Waiver and Community Living Supports (CLS) under the Supports for Community Living (SCL) Waiver. Providers seeking to offer these socialization and supervision services must obtain certification as a Medicaid Waiver Provider and, depending on their structure, secure a Personal Services Agency (PSA) license from the Office of Inspector General (OIG).
The mandatory prerequisite for new agencies is obtaining an approved Medicaid Waiver Provider Certification from the Department for Aging and Independent Living (DAIL) or the Department for Behavioral Health, Developmental and Intellectual Disabilities (DBHDID) before initiating the Medicaid enrollment process in the Medicaid Partner Portal Application (MPPA). Agencies must also navigate the Medicaid Waiver Management Application (MWMA) for participant tracking and service authorization.
1. Service Definition and Scope
Because Kentucky does not use the term "Adult Companion Services" in its current 1915(c) waivers, providers deliver equivalent non-medical supervision and socialization through Home and Community Support Services (HCSS) or Community Living Supports (CLS). These services are designed to allow individuals to remain safely in their homes and communities.
The scope of these services includes assistance with activities of daily living, socialization, and supervision to ensure safety, but strictly excludes skilled nursing care or medical treatments.
- Service Name: Home and Community Support Services (HCSS) and Community Living Supports (CLS)
- Target Population: Elderly adults and individuals with physical disabilities (HCB Waiver), and individuals with intellectual/developmental disabilities (SCL/MPW)
- Covered Activities: Non-medical supervision, socialization, assistance with activities of daily living (ADLs), and community integration
- Excluded Activities: Skilled nursing care, medical treatments, and facility-based adult day health care
2. Regulatory and Oversight Agencies
The Cabinet for Health and Family Services (CHFS) serves as the umbrella agency for all Medicaid and licensing functions in Kentucky. Within CHFS, specific departments handle the distinct phases of licensure, waiver operation, and Medicaid enrollment.
The Office of Inspector General handles facility and agency licensing, while DAIL and DBHDID manage the day-to-day operations of the specific waivers that fund companion-style services.
- Cabinet for Health and Family Services (CHFS): Umbrella agency overseeing all Medicaid and licensing (https://www.chfs.ky.gov/)
- Department for Medicaid Services (DMS): Administers the Medicaid program and sets waiver policy (https://chfs.ky.gov/agencies/dms/)
- Office of Inspector General (OIG): Issues Personal Services Agency (PSA) licenses and conducts regulatory surveys (https://chfs.ky.gov/agencies/os/oig/)
- Department for Aging and Independent Living (DAIL): Operates the HCB Waiver and certifies providers (https://chfs.ky.gov/agencies/dail/)
- Department for Behavioral Health, Developmental and Intellectual Disabilities (DBHDID): Operates the SCL and MPW waivers (https://dbhdid.ky.gov/)
3. Gatekeeping Prerequisites: Who Can Even Apply
Kentucky requires specific structural preconditions to be met before an agency can bill Medicaid for non-medical support services. A provider cannot simply enroll in Medicaid; they must first pass through state-level programmatic certification.
While Kentucky does not require a Certificate of Need (CON) for non-medical companion services, the waiver certification process acts as the primary gatekeeper.
- Waiver Certification Gate: Applicants must receive programmatic approval and certification from DAIL (for HCB) or DBHDID (for SCL/MPW) before Medicaid enrollment is permitted
- Licensure Prerequisite: Entities providing non-medical in-home services must hold an active Personal Services Agency (PSA) license from CHFS OIG or a Home Health Agency license prior to waiver certification
- Certificate of Need (CON): Not required for Personal Services Agencies providing strictly non-medical companion/support services
- Moratoria: There are currently no active statewide moratoria on enrolling new HCSS or CLS providers in Kentucky
4. Licensure and Certification Requirements
To provide in-home non-medical services, agencies typically must obtain a Personal Services Agency (PSA) license from the CHFS Office of Inspector General. This license ensures the agency meets basic state health and safety standards.
Once licensed, the agency must apply for waiver-specific certification to prove they can meet the additional requirements of the HCB, SCL, or MPW waivers.
- License Type: Personal Services Agency (PSA) license issued by CHFS OIG
- Regulation Citation: 906 KAR 1:180 governs the operation and licensure of PSAs in Kentucky
- Application Form: OIG-144 (Application for Licensure to Operate a Personal Services Agency)
- Licensure Fee: Typically $125 for initial PSA licensure and annual renewal
5. Medicaid Provider Enrollment
After obtaining the necessary license and waiver certification, providers must enroll in Kentucky Medicaid using the Medicaid Partner Portal Application (MPPA).
Providers must also register for the Medicaid Waiver Management Application (MWMA), which is the mandatory state system for managing waiver participant care plans and service authorizations.
- Enrollment Portal: Kentucky Medicaid Partner Portal Application (MPPA) (https://chfs.ky.gov/agencies/dms/provider/)
- Provider Type: Enrolled as a Waiver Provider (PT 32) or Home and Community Based Waiver Provider depending on the specific waiver
- Application Fee: Subject to the federal Medicaid application fee unless waived by Medicare enrollment
- System Requirement: Must register for and utilize the Medicaid Waiver Management Application (MWMA) for participant management
6. Staffing, Training and Background Checks
Kentucky mandates strict background checks and training requirements for all direct care staff providing HCSS or CLS. Staff must be cleared before they can have independent contact with waiver participants.
Training must cover waiver-specific topics, participant rights, and emergency procedures.
- Minimum Age: Direct care staff providing HCSS or CLS must be at least 18 years of age
- Education: Must possess a high school diploma, GED, or demonstrate ability to communicate and follow instructions effectively
- Background Checks: Mandatory Kentucky State Police criminal background check and check of the Kentucky Child/Adult Abuse Registry (KAAR/CAN)
- Training: Must complete CPR/First Aid certification and waiver-specific training on participant rights and abuse reporting prior to independent client contact
7. Documentation, Policies and Records
Providers must maintain detailed records of all services delivered to justify Medicaid billing. Kentucky relies heavily on the MWMA system for care plan documentation.
Agencies must have written policies covering incident reporting, participant rights, and emergency management.
- Care Plans: Services must be delivered strictly according to the approved Plan of Care documented in MWMA
- Service Logs: Must maintain daily electronic or written logs detailing start/stop times, activities performed, and participant response
- Incident Reporting: Critical incidents must be reported via MWMA within 24 hours of discovery
- Record Retention: Kentucky requires Medicaid providers to retain all service and billing records for a minimum of five years
8. Billing, Rates and Claims
Claims for HCSS and CLS are submitted through the Kentucky Medicaid MMIS or to the participant's Managed Care Organization (MCO), depending on how the participant's benefits are administered.
Rates are standardized by DMS and published in the official waiver fee schedules.
- Billing System: Claims are submitted through the Kentucky Medicaid MMIS or via contracted Managed Care Organizations (MCOs)
- Procedure Codes: HCSS is typically billed using S5125 (Attendant Care Services) or T2013 (Companion Care) depending on the specific waiver appendix
- Unit of Service: Services are generally billed in 15-minute increments
- Rate Setting: Rates are established by DMS and published in the HCBS Waiver Fee Schedule on the CHFS website
9. Approval Sequence and Timeline
Becoming a fully approved provider is a multi-step process that must be completed in a specific order. Agencies cannot skip ahead to Medicaid enrollment without first securing their license and certification.
The entire process from initial application to active billing status can take several months.
- Step 1: Submit PSA licensure application (OIG-144) to CHFS OIG (approx. 30-60 days)
- Step 2: Apply for waiver certification through DAIL or DBHDID (approx. 60-90 days)
- Step 3: Complete Medicaid enrollment via MPPA (approx. 30-45 days)
- Step 4: Complete MWMA onboarding and MCO credentialing (approx. 60-90 days)
10. Common Denials and Survey Findings
During OIG surveys or waiver recertification reviews, providers frequently face citations for documentation and staffing compliance issues.
Medicaid enrollment applications in MPPA are often rejected due to simple data mismatches.
- Background Check Failures: Allowing staff to provide services before the KAAR/CAN registry checks are fully returned
- Documentation Gaps: Missing start/stop times or signatures on daily service logs
- Training Deficiencies: Expired CPR/First Aid certifications for direct care staff
- Application Errors: Mismatched NPI, Tax ID, or ownership information between the OIG license and MPPA enrollment
11. Key Contacts and Resources
Providers should rely on the official CHFS portals and department websites for the most current forms, fee schedules, and regulatory updates.
Help desks are available for technical assistance with the MPPA and MWMA systems.
- CHFS Provider Information: https://chfs.ky.gov/agencies/dms/provider/
- Medicaid Partner Portal Application (MPPA): https://chfs.ky.gov/agencies/dms/provider/Pages/mppa.aspx
- Office of Inspector General (OIG): https://chfs.ky.gov/agencies/os/oig/
- Department for Aging and Independent Living (DAIL): https://chfs.ky.gov/agencies/dail/
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