Kentucky - Skilled Respite Service — Licensing, Medicaid Enrollment and Startup Requirements

Last reviewed: 2026-08-15

In Kentucky, "Skilled Respite" is not issued as a standalone facility or agency license. Instead, it is a specialized service authorized under the state's Home and Community Based Services (HCBS) waivers—such as the Home and Community Based (HCB) waiver, Supports for Community Living (SCL), and the Michelle P. Waiver (MPW). It is delivered by licensed nursing staff (RNs or LPNs) to provide temporary relief for unpaid caregivers of participants with complex medical needs. Providers must first hold an underlying appropriate license, such as a Home Health Agency license or an Adult Day Health Care license, before enrolling as a Medicaid waiver provider.

The single biggest structural barrier to entry for this service in Kentucky is the state's strict waiver enrollment hierarchy and managed care credentialing mandate. Specifically, an agency cannot enroll as a standalone provider for the Michelle P. Waiver (MPW); they must first be fully enrolled and active as an HCB or SCL waiver provider. Furthermore, obtaining a Kentucky Medicaid ID is only the first step; because most waiver services are managed by Managed Care Organizations (MCOs), providers cannot receive referrals or bill until they successfully complete separate credentialing with up to six different MCOs operating in their target counties.

1. Service Definition and Scope

Skilled Respite in Kentucky provides short-term, temporary relief to the primary unpaid caregiver of a Medicaid waiver participant. Unlike basic respite, skilled respite is specifically authorized for individuals whose medical acuity requires interventions that exceed the capabilities of an unlicensed direct care worker.

The service must be delivered by a licensed nurse and is governed by the specific regulations of the participant's waiver program, such as 907 KAR 7:010 for the HCB waiver. It can be provided in the participant's home or in a licensed Adult Day Health Care center.

• Service Category: HCBS Waiver Respite Care (Skilled).
• Applicable Waivers: Home and Community Based (HCB), Michelle P. Waiver (MPW), and Supports for Community Living (SCL).
• Scope of Practice: Includes medication administration, wound care, tube feeding, and other clinical tasks requiring a nursing license.
• Eligible Settings: The participant's private residence or a state-licensed Adult Day Health Care facility.
• Exclusions: Cannot be billed concurrently with other waiver services, during times the primary caregiver is working, or for room and board costs.

2. Regulatory and Oversight Agencies

The Kentucky Cabinet for Health and Family Services (CHFS) serves as the umbrella organization overseeing all Medicaid and facility licensing in the state. Within CHFS, responsibilities are divided between policy administration and regulatory enforcement.

The Department for Medicaid Services (DMS) manages waiver rules and provider enrollment, while the Office of Inspector General (OIG) conducts surveys and issues the underlying facility or agency licenses required to operate.

• Umbrella Agency: Kentucky Cabinet for Health and Family Services (CHFS).
• Medicaid Authority: Department for Medicaid Services (DMS), Division of Long-Term Services and Supports (LTSS).
• Licensing Body: CHFS Office of Inspector General (OIG), Division of Health Care.
• Background Screening: Kentucky Applicant Registry and Employment Screening (KARES) program.
• Managed Care Oversight: Individual MCO credentialing committees (e.g., Aetna Better Health of KY, Humana Healthy Horizons, WellCare).

3. Gatekeeping Prerequisites: Who Can Even Apply

Kentucky does not offer a distinct "Skilled Respite Provider" license. To offer this service, an entity must first secure an underlying operational license (like a Home Health Agency) and then apply for waiver provider status. The state enforces strict structural preconditions that block applications if not met.

The most significant gatekeeping rule is the waiver hierarchy for the Michelle P. Waiver (MPW). Additionally, state Medicaid enrollment does not grant immediate billing rights; providers must navigate a closed-loop EVV integration and MCO contracting process.

• MPW Prerequisite: Agencies cannot enroll solely as Michelle P. Waiver (MPW) providers; they must first be enrolled and active as HCB or SCL waiver providers.
• Licensure Prerequisite: Must hold an active Kentucky Home Health Agency license (for in-home care) or Adult Day Health Care license (for facility-based care) before Medicaid waiver enrollment is permitted.
• MCO Network Access: State Medicaid enrollment is only step one; providers must successfully credential with the active MCOs in their target counties to receive authorizations and bill.
• EVV Integration Gate: Must have a completed, active integration with Therap (Kentucky's state-designated EVV aggregator) to process any in-home claims.
• Business Registration: Must be registered with the Kentucky Secretary of State and possess a Federal Tax ID (EIN) and National Provider Identifier (NPI).

4. Licensure and Certification Requirements

Because Skilled Respite is a waiver service, the licensure requirements depend on the setting in which the care is delivered. Providers must comply with the Kentucky Administrative Regulations (KAR) governing their specific agency type.

In-home skilled respite is typically delivered by agencies licensed as Home Health Agencies, while facility-based skilled respite is delivered by Adult Day Health Care centers. Both require rigorous initial surveys by the OIG.

• Governing Waiver Regulation: 907 KAR 7:010 (Home and Community Based Waiver Services).
• Home Health Licensure: 902 KAR 20:081 (required if providing skilled nursing in the home via a home health agency model).
• Adult Day Health Licensure: 902 KAR 20:066 (required if providing skilled respite in an adult day setting).
• Insurance Requirements: Must maintain general and professional liability insurance meeting CHFS minimum coverage standards.
• Application Routing: OIG licensure applications and architectural plans (if facility-based) are submitted directly to the CHFS Office of Inspector General.

5. Medicaid Provider Enrollment

Kentucky utilizes a mandatory two-step enrollment process for HCBS providers. The first step is obtaining a state Medicaid ID through the Kentucky Medicaid Partner Portal Application (KY MPPA).

Once the state ID is issued, the provider must complete the second step: credentialing with the individual Managed Care Organizations (MCOs) that administer the waiver benefits for the majority of Kentucky Medicaid recipients.

• Enrollment System: Kentucky Medicaid Partner Portal Application (KY MPPA) accessed via the KYHealthNet portal.
• Provider Type: Must enroll under the specific waiver provider type (e.g., Provider Type 32 for Waiver Services).
• Application Fee: Subject to the CMS institutional provider application fee (approximately $731) unless waived by prior Medicare enrollment.
• Required Identifiers: Must submit a National Provider Identifier (NPI) and taxonomy code matching the skilled nursing/respite service.
• Revalidation: Required every five years through the KY MPPA system to maintain active status.

6. Staffing, Training and Background Checks

Skilled respite requires clinical licensure; it cannot be performed by standard direct support professionals or personal care aides. All staff must meet Kentucky Board of Nursing standards and pass strict state background checks.

Agencies must maintain active files proving that all clinical staff have unencumbered licenses and have completed mandatory safety and waiver-specific training before their first shift.

• Clinical Qualifications: Must hold an active, unencumbered Registered Nurse (RN) or Licensed Practical Nurse (LPN) license from the Kentucky Board of Nursing.
• Basic Certifications: Current CPR and First Aid certifications are required for all staff providing direct care.
• Background Check System: Mandatory processing through the Kentucky Applicant Registry and Employment Screening (KARES) system.
• Disqualifying Offenses: Convictions for abuse, neglect, exploitation, or certain felonies permanently bar employment under CHFS regulations.
• Supervision: LPNs providing skilled respite must be supervised by an RN in accordance with the Kentucky Board of Nursing scope of practice.

7. Documentation, Policies and Records

Kentucky Medicaid and the OIG require rigorous documentation to justify the billing of skilled services. Providers must maintain detailed clinical records that align exactly with the participant's person-centered service plan.

For in-home skilled respite, Electronic Visit Verification (EVV) is federally mandated and strictly enforced by Kentucky DMS. Paper timesheets are not acceptable for in-home waiver services.

• Service Plan Alignment: Services must be explicitly authorized in the participant's person-centered service plan prior to delivery.
• Visit Documentation: Must record the date, arrival/departure times, duration, a specific description of the skilled service provided, and the staff signature (per 907 KAR 7:010).
• EVV Mandate: All in-home respite visits must be logged via an EVV system that feeds directly into Therap.
• Record Retention: Clinical and billing records must be retained for a minimum of six years per Kentucky Medicaid rules.
• Incident Reporting: Critical incidents must be reported to CHFS and the participant's MCO within 24 hours of occurrence.

8. Billing, Rates and Claims

Because Kentucky delivers most Medicaid services through managed care, providers rarely bill the state directly (fee-for-service) for waiver respite. Instead, claims are submitted to the participant's assigned MCO.

Kentucky implemented hard EVV edits in January 2025. Claims submitted to MCOs that do not have a perfectly matching EVV record in the state's Therap aggregator will be automatically denied.

• Billing Destination: Claims are submitted to the participant's MCO (e.g., WellCare, Anthem, Aetna) rather than KYHealthNet.
• EVV Hard Edits: As of January 2025, claims without matching Therap EVV visit records are automatically denied.
• Prior Authorization: Skilled respite requires prior authorization from the MCO or state utilization management contractor before service delivery.
• Rate Structure: Reimbursed in 15-minute increments; base rates are set by DMS, though MCOs may negotiate specific contract rates.
• Coding: Claims must include appropriate HCPCS codes (e.g., T1005 for respite) and waiver-specific modifiers indicating skilled nursing level.

9. Approval Sequence and Timeline

Becoming a fully billable skilled respite provider in Kentucky is a lengthy, sequential process. Providers cannot begin the next phase until the previous phase is fully approved and documented.

The entire runway typically takes 6 to 9 months, heavily dependent on OIG survey schedules and the processing times of the individual MCO credentialing committees.

• Step 1: Business formation and OIG Licensure (e.g., Home Health Agency or Adult Day Health) (3-6 months).
• Step 2: KY MPPA State Medicaid Enrollment (30-60 days).
• Step 3: MCO Credentialing and Contracting (90-120 days per MCO, done concurrently).
• Step 4: EVV Integration with Therap (2-4 weeks).
• Total Estimated Timeline: 6 to 9 months from initial OIG application to the first billable MCO claim.

10. Common Denials and Survey Findings

Applications and claims are frequently delayed or denied due to administrative errors, failure to understand Kentucky's waiver hierarchy, or EVV technical failures.

During OIG surveys, agencies are most commonly cited for documentation failures, particularly regarding the specific clinical justification for skilled nursing tasks during a respite shift.

• Enrollment Denial: Applying for MPW provider status without first holding an active HCB or SCL waiver enrollment.
• Claim Denial (EVV): Mismatches between the EVV clock-in location/time and the submitted claim, or failure to route EVV data through Therap.
• Survey Citation: Incomplete sign-in/sign-out logs lacking the specific description of the skilled service provided.
• Credentialing Delay: Submitting MCO credentialing applications before the KY MPPA state enrollment is fully approved and active.
• Survey Citation: LPNs operating without documented RN supervision or performing tasks outside the nursing scope of practice.

11. Key Contacts and Resources

Providers should rely on official CHFS portals, the KY MPPA contact center, and the designated EVV vendor for authoritative guidance on enrollment and billing.

Maintaining direct contact with MCO provider relations representatives is also critical for resolving credentialing and claims issues.

• KY MPPA Contact Center: (877) 838-5085 for Medicaid enrollment technical support and policy inquiries.
• CHFS Office of Inspector General (OIG): For agency licensure, architectural plan reviews, and regulatory compliance inquiries.
• KYHealthNet Portal: https://public.kymmis.com/kyhealthnet for provider enrollment access.
• Therap Services: Kentucky's designated EVV aggregator for integration support and training.
• Kentucky Board of Nursing: For verifying RN/LPN license status and scope of practice regulations.

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