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

Last reviewed: 2026-09-10

Kentucky licenses entities providing hands-on assistance with bathing, dressing, transferring, and toileting in a client's own home as Personal Services Agencies (PSAs) under 902 KAR 20:380, overseen by the Cabinet for Health and Family Services (CHFS) Office of Inspector General (OIG). These services are funded primarily through the Department for Medicaid Services (DMS) under the Home and Community Based (HCB) Waiver and the Michelle P. Waiver.

Prospective providers must obtain a finalized PSA license from the OIG before the Kentucky Medicaid Partner Portal will accept a provider enrollment application. Following state Medicaid enrollment, agencies must secure active network contracts with the regional Managed Care Organizations (MCOs) to receive reimbursement for waiver participants.

1. Service Definition and Scope

In Kentucky, Personal Assistance Services encompass non-medical, hands-on care provided to individuals in their own homes to support activities of daily living (ADLs) and instrumental activities of daily living (IADLs). The state defines these services formally under the Personal Services Agency licensure regulations and the Medicaid waiver service definitions.

Providers must operate within the scope of their PSA license, meaning they cannot provide skilled nursing or medical services unless they are also licensed as a Home Health Agency under 902 KAR 20:081.

• Service Category: Personal Assistance Services under the HCB and Michelle P. Waivers.
• ADL Support: Includes hands-on assistance with bathing, dressing, grooming, toileting, and transferring.
• IADL Support: Includes light housekeeping, meal preparation, and shopping when incidental to personal care.
• Exclusions: Skilled nursing, medication administration (unless specifically delegated under nursing board rules), and medical therapies.
• Setting: Services must be delivered in the participant's private residence, not in a licensed congregate facility.

2. Regulatory and Oversight Agencies

The Cabinet for Health and Family Services (CHFS) is the umbrella agency responsible for both licensure and Medicaid administration in Kentucky. Within CHFS, distinct divisions handle facility licensing, Medicaid policy, and program integrity.

Providers interact with the Office of Inspector General for initial and ongoing licensure, and the Department for Medicaid Services for enrollment and waiver compliance.

• Licensing Authority: CHFS Office of Inspector General (OIG) (https://chfs.ky.gov/agencies/os/oig).
• Medicaid Agency: CHFS Department for Medicaid Services (DMS) (https://chfs.ky.gov/agencies/dms).
• Enrollment Portal: Kentucky Medicaid Partner Portal (https://medicaidsystems.ky.gov/Partnerportal/home.aspx).
• Waiver Oversight: Division of Community Alternatives (DCA) (https://chfs.ky.gov/agencies/dms/dca).
• Managed Care Organizations: Entities like Aetna, Anthem, Humana, Passport, UnitedHealthcare, and Wellcare that manage member benefits.

3. Gatekeeping Prerequisites: Who Can Even Apply

Kentucky requires a sequential approval process where structural prerequisites must be met before Medicaid enrollment is possible. The state does not currently impose a Certificate of Need (CON) for Personal Services Agencies, unlike Home Health Agencies.

An applicant cannot submit a Medicaid enrollment application without first holding an active, valid license from the CHFS OIG.

• Licensure Prerequisite: Must hold an active Personal Services Agency (PSA) license from CHFS OIG before Medicaid enrollment.
• Physical Location: Must maintain a physical business office in Kentucky or a border state if serving border counties.
• MCO Contracting: Must secure contracts with Kentucky Medicaid MCOs to bill for most waiver services.
• NPI Requirement: Must obtain a National Provider Identifier (NPI) specific to the agency location.
• Background Clearances: Owners and managing employees must pass background checks prior to licensure approval.

4. Licensure and Certification Requirements

Personal Services Agencies are licensed under 902 KAR 20:380. The application process requires submitting detailed operational policies, proof of insurance, and a designated agency manager.

The OIG conducts an initial on-site survey to verify compliance with administrative regulations before issuing the final license.

• Regulation Citation: 902 KAR 20:380 establishes minimum licensure requirements for PSAs.
• Application Form: Application for License to Operate a Health Facility or Health Service submitted to OIG.
• Licensure Fee: Initial and annual renewal fees are required (typically $500 for outpatient/agency categories).
• Agency Manager: Must designate a qualified manager responsible for daily operations.
• Initial Survey: OIG conducts an on-site inspection prior to issuing the permanent license.

5. Medicaid Provider Enrollment

Once licensed, the agency must enroll as a Kentucky Medicaid provider through the Kentucky Medicaid Partner Portal. Enrollment is governed by 907 KAR 1:671 and 907 KAR 1:672.

Providers must submit the MAP-347 form and complete all ownership disclosures. Enrollment can take up to 90 days.

• Enrollment System: Kentucky Medicaid Partner Portal.
• Regulation: 907 KAR 1:671 and 907 KAR 1:672 govern provider enrollment.
• Required Form: MAP-347 (Statement of Authorization for Payment).
• Application Fee: Must pay the federal Medicaid application fee unless waived by Medicare enrollment.
• Processing Time: DMS states the enrollment process may take up to 90 days.

6. Staffing, Training and Background Checks

Kentucky mandates strict background checks and training for all direct care staff providing personal assistance. Agencies must verify staff against state abuse registries before hire.

Staff must complete initial orientation and annual continuing education covering client rights, infection control, and emergency procedures.

• Registry Checks: Must check the Kentucky Nurse Aide Abuse Registry and Caregiver Misconduct Registry.
• Criminal Background: State police criminal background check required for all direct care staff.
• CPR/First Aid: Direct care staff must hold current CPR and First Aid certification.
• Initial Training: Must complete agency orientation prior to providing independent client care.
• TB Testing: Staff must provide proof of negative tuberculosis screening upon hire.

7. Documentation, Policies and Records

PSAs must maintain comprehensive client and employee records. Client records must include a detailed service plan developed prior to the initiation of care.

Electronic signatures are permitted if they comply with KRS 369.101 to 369.120 and the agency has a written security policy.

• Service Plan: Must document the type, frequency, and duration of services requested.
• Visit Notes: Staff must document date, start/stop times, and specific ADLs assisted with during each shift.
• Record Retention: Records must be kept for a minimum of five years from the last date of service.
• Electronic Signatures: Permitted under KRS 369.102(8) with compliant security policies.
• Incident Reporting: Must have policies for documenting and reporting client injuries or abuse.

8. Billing, Rates and Claims

Reimbursement for Personal Assistance Services is primarily handled through the Medicaid MCOs. Providers must submit claims directly to the MCO the member is enrolled with.

Rates are established by DMS but administered by the MCOs. Providers cannot bill for services provided by more than one provider during the same time period.

• Billing System: Claims are submitted to the respective MCO's clearinghouse.
• Duplication of Service: 907 KAR 1:030 prohibits billing for overlapping services during the same time period.
• Prior Authorization: Required by MCOs for services exceeding standard waiver limits.
• Third Party Liability: Providers must comply with KRS 205.622 regarding third-party billing.
• Appeals: Denied FFS claims are appealed to DMS; MCO denials are appealed to the specific MCO.

9. Approval Sequence and Timeline

The path to becoming a billing provider involves three distinct phases: state licensure, Medicaid enrollment, and MCO credentialing. Each phase must be completed sequentially.

The entire process from submitting the licensure application to receiving the first MCO contract can take 6 to 9 months.

• Phase 1: Submit PSA license application to CHFS OIG (30-60 days).
• Phase 2: Pass OIG initial on-site survey and receive license (30 days).
• Phase 3: Submit Medicaid enrollment via Partner Portal (up to 90 days).
• Phase 4: Receive Medicaid Provider ID and welcome letter.
• Phase 5: Apply for credentialing and contracting with MCOs (90-120 days).

10. Common Denials and Survey Findings

Applications and surveys are frequently delayed or denied due to incomplete documentation or failure to adhere to strict regulatory timelines.

During OIG surveys, agencies often face citations for inadequate personnel files or missing registry checks.

• Enrollment Denial: Outstanding accounts receivable or debts to the state will block Medicaid approval.
• Survey Citation: Failure to check the Caregiver Misconduct Registry prior to hire.
• Survey Citation: Incomplete client service plans lacking specific ADL instructions.
• Application Return: Missing ownership disclosures or incorrect NPI linkages on the MAP-347.
• Plan of Correction: If cited by OIG, the agency must submit an acceptable plan within 10 days.

11. Key Contacts and Resources

Providers should utilize the official CHFS portals and MCO provider relations departments for guidance. The Division of Program Integrity handles enrollment inquiries.

Regulatory updates are published in the Kentucky Administrative Register and via DMS provider bulletins.

• Provider Enrollment (DMS): [email protected] or (877) 838-5085.
• Kentucky Medicaid Partner Portal: https://medicaidsystems.ky.gov/Partnerportal/home.aspx
• CHFS OIG Licensure: https://chfs.ky.gov/agencies/os/oig
• Anthem Provider Network: https://mediproviders.anthem.com/ky/pages/home.aspx
• Humana Provider Network: https://www.humana.com/medicaid/kentucky-medicaid

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