Massachusetts - Adult Companion Services — Licensing, Medicaid Enrollment and Startup Requirements

Last reviewed: 2026-09-10

Adult Companion Services in Massachusetts are funded primarily through the Frail Elder Waiver (FEW) overseen by the Executive Office of Elder Affairs (EOEA) and the Department of Developmental Services (DDS) waivers, requiring providers to bypass standard Medicaid enrollment and first secure contracts with regional designating entities. The service provides non-medical supervision, socialization, and assistance with instrumental activities of daily living (IADLs) to ensure individuals can safely remain in their community settings.

Approval requires navigating distinct procurement channels rather than obtaining a standalone state license, as Massachusetts does not issue a specific facility or agency license for companion care. An applicant must either win a contract with one of the state's 25 Aging Services Access Points (ASAPs) for elder services or successfully respond to a DDS Request for Responses (RFR) on COMMBUYS before the Provider Online Service Center (POSC) will process a MassHealth enrollment application.

1. Service Definition and Scope

In Massachusetts, Adult Companion Services consist of non-medical care, supervision, and socialization provided to a waiver participant. Providers assist with instrumental activities of daily living (IADLs) such as meal preparation, laundry, and light housekeeping, provided these activities are incidental to the primary goal of supervision and socialization.

This service explicitly excludes hands-on personal care, such as bathing, dressing, or medication administration, which fall under Homemaker or Personal Care services. It is designed to prevent institutionalization by ensuring the participant's health and safety in their home when primary caregivers are unavailable.

• Target Population: Adults aged 60 and older on the Frail Elder Waiver, or adults with intellectual/developmental disabilities on DDS waivers.
• Included Activities: Socialization, playing games, reading, accompanying the participant to community appointments, and incidental light housekeeping.
• Excluded Activities: Hands-on activities of daily living (ADLs), medical treatments, and skilled nursing tasks.
• Setting Limitations: Delivered in the participant's private residence or community settings, not in provider-owned congregate facilities.
• Service Limits: Authorized hours are strictly dictated by the participant's individualized service plan developed by the ASAP or DDS service coordinator.

2. Regulatory and Oversight Agencies

The Executive Office of Health and Human Services (EOHHS) serves as the single state Medicaid agency (MassHealth) and sets the overarching regulations and rates for HCBS waivers. However, day-to-day oversight and provider credentialing are delegated to specific operating agencies based on the target population.

The Executive Office of Elder Affairs (EOEA) manages the Frail Elder Waiver through regional ASAPs, while the Department of Developmental Services (DDS) and the Massachusetts Rehabilitation Commission (MRC) manage waivers for individuals with intellectual disabilities and brain injuries, respectively.

• MassHealth (EOHHS): Administers the Medicaid program, sets rates, and manages the Provider Online Service Center (POSC) (https://www.mass.gov/topics/masshealth).
• Executive Office of Elder Affairs (EOEA): Operates the Frail Elder Waiver and oversees the ASAP network (https://www.mass.gov/orgs/executive-office-of-elder-affairs).
• Department of Developmental Services (DDS): Operates the Community Living and Adult Supports waivers and conducts provider licensure/certification (https://www.mass.gov/orgs/department-of-developmental-services).
• Massachusetts Rehabilitation Commission (MRC): Operates the Traumatic Brain Injury and Acquired Brain Injury waivers (https://www.mass.gov/orgs/massachusetts-rehabilitation-commission).
• Aging Services Access Points (ASAPs): 25 regional non-profits that contract directly with providers for elder services (https://www.mass.gov/aging-services-access-points-asaps-programs).

3. Gatekeeping Prerequisites: Who Can Even Apply

Massachusetts does not allow direct-to-Medicaid enrollment for Adult Companion Services. A provider cannot simply submit an application to MassHealth; they must first be procured or contracted by the specific state operating agency or its regional delegates.

For elder services, providers must apply to and win a contract with one or more of the 25 regional ASAPs during their open procurement windows. For DDS or MRC waivers, providers must respond to a formal Request for Responses (RFR) posted on the state's COMMBUYS procurement portal and be awarded a contract before MassHealth will issue a provider number.

• ASAP Network Contracting: Required for the Frail Elder Waiver; providers must pass the Notice of Intent (NOI) and administrative review process with a regional ASAP.
• DDS COMMBUYS Procurement: Required for DDS waivers; applicants must submit a qualifying response to the active HCBS Provider RFR on the state procurement site.
• Closed Network Moratoria: ASAPs may close their provider networks to new applicants if they determine they have adequate network capacity for companion services in their catchment area.
• Corporate Good Standing: Applicants must possess a Certificate of Good Standing from the Massachusetts Department of Revenue and the Secretary of the Commonwealth.
• Financial Viability: ASAP and DDS procurements require submission of audited financial statements or a CPA-reviewed business plan to prove the agency can sustain operations.

4. Licensure and Certification Requirements

The Massachusetts Department of Public Health (DPH) does not issue a specific "Adult Companion Agency" license. Because the service is non-medical, it falls outside the scope of DPH Home Health Agency licensure.

Instead of a traditional license, providers achieve certification through the operating agency's credentialing standards. For EOEA, this means adhering to the Provider Network Quality Assurance (PNQA) manual. For DDS, providers must pass the DDS Licensure and Certification process (115 CMR 8.00), which evaluates organizational capacity and service quality.

• DPH Exemption: Adult Companion providers are exempt from DPH home health licensure because they do not provide skilled nursing or hands-on ADL care.
• EOEA PNQA Certification: Providers must pass an initial and biennial administrative review by their contracting ASAP to ensure compliance with EOEA standards.
• DDS Provider Qualification: Agencies serving DDS waivers must undergo the DDS Licensure and Certification review, typically on a 2-year cycle.
• Local Business License: Agencies must hold a standard municipal business license or permit in the Massachusetts city or town where their administrative office is located.
• Insurance Mandates: Providers must maintain general liability, professional liability, and workers' compensation insurance at levels dictated by their ASAP or DDS contracts.

5. Medicaid Provider Enrollment

Once a provider has secured an ASAP contract or a DDS/MRC contract award, they must formally enroll as a MassHealth provider to receive Medicaid reimbursement. This is done through the Provider Online Service Center (POSC).

The enrollment application requires the provider to submit their executed state or ASAP contract as proof of authorization. Without this contract, the POSC application will be automatically rejected.

• POSC Portal: All MassHealth enrollment applications must be submitted electronically through the Provider Online Service Center (https://newmmis-portal.ehs.state.ma.us/EHSProviderPortal).
• Provider Type: Applicants must select the specific HCBS Waiver Provider type and specialty code corresponding to Adult Companion Services.
• Trading Partner Agreement: Providers must sign the MassHealth Trading Partner Agreement to submit electronic claims.
• Contract Verification: The application must include the executed ASAP contract or DDS award letter as an attachment.
• Revalidation: MassHealth requires all waiver providers to revalidate their enrollment every five years, or sooner if requested.

6. Staffing, Training and Background Checks

Direct care staff providing Adult Companion Services must meet baseline qualifications established by EOEA and DDS. Because they work with vulnerable populations, strict background check requirements are enforced.

Agencies are responsible for maintaining personnel files that document all required background clearances, initial orientation, and ongoing annual training. Staff cannot begin providing billable services until all background checks are fully cleared.

• Age Requirement: Adult companions must be at least 18 years of age.
• CORI Checks: Agencies must conduct Criminal Offender Record Information (CORI) checks through the Department of Criminal Justice Information Services before hire.
• SORI Checks: Sex Offender Registry Information (SORI) checks are mandatory for all direct care staff.
• OIG Exclusion List: Agencies must verify monthly that staff are not on the federal LEIE or the MassHealth provider exclusion list.
• Basic Training: Staff must complete orientation covering elder/disabled abuse reporting (Mandated Reporter), emergency procedures, and basic communication skills.
• TB Testing: Staff must provide documentation of a negative Tuberculosis (TB) screening prior to direct client contact.

7. Documentation, Policies and Records

Massachusetts requires HCBS providers to maintain comprehensive records in accordance with 130 CMR 450.000 (MassHealth Administrative and Billing Regulations). Documentation must clearly link the services provided to the participant's authorized service plan.

Providers must implement written policies covering incident reporting, grievance procedures, and participant rights. Records must be retained for a minimum of six years after the date of service.

• Service Plans: The agency must maintain a copy of the ASAP or DDS-approved individualized service plan detailing authorized companion hours.
• Progress Notes: Staff must document the specific activities performed, the participant's response, and the start/end times for every shift.
• Incident Reporting: Agencies must have a policy to report critical incidents (e.g., falls, suspected abuse) to the ASAP or DDS within 24 hours.
• Timesheets: Signed timesheets or electronic visit verification (EVV) logs must be maintained to support all billed claims.
• Record Retention: All clinical and billing records must be securely stored and retained for at least six years.

8. Billing, Rates and Claims

Rates for Adult Companion Services are established by EOHHS under 101 CMR 359.00 (Rates for Home and Community Based Services Waivers). Providers cannot bill MassHealth directly for Frail Elder Waiver services; instead, they bill the contracting ASAP or Senior Care Organization (SCO), which then bills MassHealth.

For DDS and MRC waivers, providers bill MassHealth directly through the POSC or via an approved clearinghouse. All claims must comply with Electronic Visit Verification (EVV) mandates.

• Rate Regulation: EOHHS sets the maximum allowable rates under 101 CMR 359.00, which are updated periodically.
• Procedure Code: Adult Companion Services are typically billed using HCPCS code S5135 (Companion care, adult).
• Billing Increments: Services are generally billed in 15-minute units, strictly limited to the hours authorized in the service plan.
• EVV Mandate: Providers must use an Electronic Visit Verification system to record the date, time, and location of service delivery.
• Third-Party Liability: Providers must bill any applicable third-party insurance before submitting claims to the ASAP or MassHealth.

9. Approval Sequence and Timeline

Becoming an Adult Companion provider in Massachusetts is a multi-step process that can take 6 to 12 months, depending on procurement cycles. The process begins with establishing a legal business entity and monitoring COMMBUYS or ASAP websites for open enrollment periods.

Once a bid is submitted, the operating agency conducts an administrative and financial review. If awarded, the provider then completes the MassHealth POSC enrollment, which adds another 30 to 60 days to the timeline.

• Entity Formation: Register the business with the MA Secretary of the Commonwealth and obtain an EIN and NPI (1-4 weeks).
• Procurement Monitoring: Identify open RFRs on COMMBUYS or contact local ASAPs for Notice of Intent windows (variable).
• Application Submission: Submit the comprehensive proposal, financial documents, and policies to the ASAP or DDS (30-60 days for state review).
• Contract Execution: Sign the provider agreement with the ASAP or state agency upon approval (2-4 weeks).
• MassHealth Enrollment: Submit the POSC application with the executed contract attached (30-60 days for MassHealth processing).

10. Common Denials and Survey Findings

Applications are most frequently denied at the gatekeeping stage because a provider attempts to apply to an ASAP that has a closed network, or they fail to meet the strict financial viability standards required during the procurement phase.

During audits or credentialing reviews, providers are commonly cited for failing to maintain complete personnel files, particularly missing or expired CORI checks, or for billing discrepancies where EVV data does not match submitted claims.

• Closed ASAP Networks: Application rejected because the regional ASAP is not currently accepting new companion providers.
• Incomplete CORI: Citations issued when staff provide services before a CORI check is fully returned and cleared.
• Missing EVV Data: Claims denied or recouped because the electronic visit verification log is missing or lacks GPS location data.
• Unapproved ADL Care: Citations for scope-of-practice violations when companion staff are found providing hands-on personal care.
• Lapsed Training: Audit findings for failing to ensure staff complete their mandatory annual in-service training.

11. Key Contacts and Resources

Prospective providers must utilize state-specific portals and agency contacts to navigate the procurement and enrollment process. The COMMBUYS system is essential for finding DDS and MRC solicitations.

For elder services, providers should locate their regional ASAP using the state's directory. MassHealth Provider Services is available to assist with the technical aspects of POSC enrollment once a contract is secured.

• MassHealth Provider Services: Handles POSC enrollment and MMIS technical support (https://www.mass.gov/masshealth-provider-services).
• COMMBUYS: The official procurement record system for Massachusetts where DDS/MRC RFRs are posted (https://www.commbuys.com).
• MassOptions (ASAP Directory): Tool to locate the specific Aging Services Access Point for a given municipality (https://www.massoptions.org).
• EOEA Provider Network Quality Assurance: Guidelines for ASAP contracting and provider standards (https://www.mass.gov/orgs/executive-office-of-elder-affairs).
• DDS Provider Licensure and Certification: Information on the 115 CMR 8.00 review process (https://www.mass.gov/dds-licensure-and-certification).

See all Massachusetts services · Massachusetts Medicaid consulting · book a consultation.