Massachusetts - Personal Emergency Response System — Licensing, Medicaid Enrollment and Startup Requirements

Last reviewed: 2026-09-10

MassHealth covers Personal Emergency Response System (PERS) installations and monitoring under 130 CMR 409.429 and through 10 distinct Home- and Community-Based Services (HCBS) waivers, including the Frail Elder and Traumatic Brain Injury waivers. The Executive Office of Health and Human Services (EOHHS) administers the Medicaid payment system, while specific waiver operating agencies manage provider qualifications and service authorizations.

Massachusetts does not issue a distinct facility or agency license for PERS providers through the Department of Public Health. Instead, the structural precondition to bill MassHealth for waiver participants requires securing a contract with a regional Aging Services Access Point (ASAP) for elder services, or responding to an active COMMBUYS procurement to become a qualified provider under the Department of Developmental Services (DDS) or Massachusetts Rehabilitation Commission (MRC) before submitting a MassHealth provider application.

1. Service Definition and Scope

Under 130 CMR 409.429, a Personal Emergency Response System (PERS) is defined as a connected electronic device that enables a MassHealth member to secure help in an emergency. The system connects to a 24-hour response center and is authorized for members who live alone or are alone for significant parts of the day and are at risk of falls or medical emergencies.

Effective July 1, 2024, per Durable Medical Equipment Bulletin 37, MassHealth explicitly covers PERS units that connect through either a traditional landline or a cellular network. Members are not required to obtain an individual cellular plan when using a cellular PERS unit, as the provider must supply the fully functional system.

• Equipment Scope: Includes the in-home communication transceiver and a wearable portable button (pendant or wristband).
• Cellular Network Inclusion: Providers may supply and bill for cellular-based units without requiring the member to hold a separate cellular contract.
• Response Center: Must be a 24-hour, seven-day-a-week monitoring facility capable of receiving signals and dispatching emergency responders or designated contacts.
• Installation Services: Includes delivery, setup, testing of the unit, and instructing the member on its use.
• Maintenance: Providers are responsible for ongoing maintenance, battery replacement, and ensuring continuous functionality of the leased equipment.

2. Regulatory and Oversight Agencies

The Massachusetts Executive Office of Health and Human Services (EOHHS) serves as the single state Medicaid agency, operating MassHealth and setting overarching provider rules. Because PERS is not a licensed health care facility type, the Department of Public Health (DPH) does not regulate or oversee these providers.

Oversight is delegated to the specific waiver operating agencies that authorize the service. Providers must adhere to the standards set by the Executive Office of Elder Affairs (EOEA) for the Frail Elder Waiver, the Department of Developmental Services (DDS) for intellectual disability waivers, and the Massachusetts Rehabilitation Commission (MRC) for brain injury waivers.

• MassHealth: Administers Medicaid enrollment, claims processing, and DME regulations (https://www.mass.gov/topics/masshealth).
• Executive Office of Elder Affairs (EOEA): Oversees the Frail Elder Waiver and the regional ASAP network (https://www.mass.gov/orgs/executive-office-of-elder-affairs).
• Department of Developmental Services (DDS): Operates HCBS waivers for adults with intellectual disabilities and manages the Provider Data Management system (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).
• Division of Health Care Facility Licensure and Certification: DPH division that explicitly does not license PERS providers, exempting them from facility licensure (https://www.mass.gov/orgs/division-of-health-care-facility-licensure-and-certification).

3. Gatekeeping Prerequisites: Who Can Even Apply

Before a provider can enroll with MassHealth to bill for PERS under HCBS waivers, they must pass through the procurement or contracting gates of the specific waiver operating agencies. There is no open-door Medicaid enrollment for waiver PERS providers without these prior affiliations.

For the Frail Elder Waiver, providers must secure a subcontract with one or more of the 25 regional Aging Services Access Points (ASAPs). For DDS and MRC waivers, providers must respond to an active Request for Responses (RFR) on the state's COMMBUYS procurement portal and be awarded a contract as a qualified provider.

• ASAP Contracting: Required affiliation with a regional Aging Services Access Point to serve Frail Elder Waiver participants; ASAPs control their own network adequacy and may close networks.
• COMMBUYS Procurement: Required response to an active state procurement for DDS or MRC waiver services; applications are only accepted when a procurement is open.
• DDS Qualification: Providers must be vetted and approved through the DDS Provider Data Management (PDM) system before MassHealth enrollment.
• Business Registration: Must be registered to do business in Massachusetts and in good standing with the Secretary of the Commonwealth.
• Medicare Enrollment: If enrolling as a general Durable Medical Equipment (DME) provider rather than strictly an HCBS waiver provider, Medicare DMEPOS enrollment is a prerequisite.

4. Licensure and Certification Requirements

Massachusetts does not license Personal Emergency Response System providers under any distinct health care facility or home health agency statute. The Department of Public Health (DPH) has no jurisdiction over the licensure of PERS businesses.

Instead of a state license, certification relies on industry-standard equipment safety ratings and the contractual standards enforced by the waiver operating agencies. Equipment must meet Underwriters Laboratories (UL) safety standards, and the response center must meet the operational criteria defined in the provider's state contract.

• DPH Licensure Exemption: No state health facility license is required or issued for PERS providers in Massachusetts.
• UL Certification: All installed PERS equipment must be Underwriters Laboratories (UL) listed or meet equivalent recognized safety standards.
• Response Center Standards: The monitoring center must have redundant power supplies, backup communication lines, and automated testing capabilities.
• Local Business License: Providers must hold standard municipal business licenses in the city or town where their physical office is located.
• Contractual Certification: Approval is granted via the execution of a provider agreement with MassHealth and the respective waiver operating agency.

5. Medicaid Provider Enrollment

Once qualified by the operating agency or ASAP, providers must enroll directly with MassHealth to receive reimbursement. Enrollment is managed by Maximus, the MassHealth Provider Enrollment and Credentialing vendor.

Providers submit their applications through the Provider Online Service Center (POSC) or by mailing a physical application requested via the Provider Application Request Form. Providers must enroll under the specific provider type designated for DME or HCBS Waiver providers.

• Provider Application Request Form: The initial online form used to request the correct MassHealth enrollment packet based on provider type.
• Maximus Credentialing: The vendor responsible for processing MassHealth provider applications and conducting federal database checks.
• Provider Online Service Center (POSC): The mandatory portal for managing enrollment data, submitting claims, and verifying member eligibility.
• National Provider Identifier (NPI): Required for enrollment, obtained from the NPPES registry.
• Electronic Funds Transfer (EFT): Mandatory setup for receiving MassHealth payments directly into a corporate bank account.

6. Staffing, Training and Background Checks

While PERS is primarily an equipment-based service, the staff who install the units and monitor the response center must meet specific background and training requirements. Massachusetts requires strict background screening for any personnel entering a waiver participant's home.

Installers must be trained on the specific equipment models and be capable of instructing members on their use. Response center staff must be trained in emergency dispatch protocols and working with individuals with cognitive or physical disabilities.

• CORI Checks: Criminal Offender Record Information checks are mandatory for all staff who visit member homes for installation or maintenance.
• Installer Identification: Field staff must carry and present clear, company-issued photo identification when arriving at a member's home.
• Response Center Staffing: The monitoring center must be staffed 24 hours a day, 365 days a year by trained dispatch personnel.
• Member Instruction: Installers must be trained to provide accessible, plain-language instruction to members and caregivers on how to test and use the device.
• Incident Reporting Training: Staff must be trained on the state's critical incident reporting protocols for HCBS waiver participants.

7. Documentation, Policies and Records

PERS providers must maintain comprehensive records to support every claim billed to MassHealth, in accordance with 130 CMR 450.000 (Administrative and Billing Regulations) and 130 CMR 409.000. Documentation must prove that the equipment was installed, tested, and actively monitored.

A specific state form is required to authorize the service. Providers must keep the completed prescription form, installation sign-off, and automated monthly testing logs in the member's file for a minimum of six years.

• PERS General Prescription Form: Must be fully completed, including Section 5 identifying the type of unit (landline or cellular), and signed by the authorizing practitioner.
• Installation Record: A document signed by the member or caregiver confirming the unit was installed, tested, and instructions were provided.
• Monthly Testing Logs: Automated or manual logs proving the unit successfully communicated with the response center each month.
• Incident Records: Documentation of every emergency button press, the response center's action, and the outcome.
• Maintenance Logs: Records of battery replacements, equipment repairs, or unit swaps.

8. Billing, Rates and Claims

PERS providers bill MassHealth directly through the Provider Online Service Center (POSC) using standard HCPCS codes. Claims are adjudicated in the Medicaid Management Information System (MMIS) and are subject to post-payment review to ensure they match the waiver Plan of Care.

Effective July 1, 2024, MassHealth updated its billing instructions for cellular PERS units. Providers must append a specific informational modifier to the standard HCPCS codes to indicate a cellular connection, while landline units are billed without the modifier.

• HCPCS Code S5160: Used to bill for the initial installation and setup of the emergency response system.
• HCPCS Code S5161: Used to bill for the ongoing monthly monitoring and maintenance of the system.
• Modifier U8: Must be appended to codes S5160, S5161, and S5162 to identify that a cellular network PERS is being used.
• Landline Billing: Billing the standard HCPCS codes without the U8 modifier indicates a traditional landline PERS unit.
• Prior Authorization: Claims will only be paid if the service is explicitly authorized in the member's approved waiver Plan of Care.

9. Approval Sequence and Timeline

Becoming a PERS provider involves a multi-step sequence that begins with the operating agency and ends with MassHealth enrollment. Providers cannot skip the procurement or ASAP contracting phase.

The timeline is heavily dependent on the state's procurement cycles. If a COMMBUYS RFR is open, qualification can take 2-4 months, followed by 30-60 days for Maximus to process the MassHealth provider enrollment application.

• Step 1: Procurement/Contracting: Respond to a COMMBUYS RFR for DDS/MRC or negotiate a subcontract with a regional ASAP.
• Step 2: Operating Agency Approval: Receive formal qualification status or an executed contract from the waiver operating agency.
• Step 3: Application Request: Submit the Provider Application Request Form to Maximus to receive the MassHealth enrollment packet.
• Step 4: MassHealth Enrollment: Submit the completed application, NPI, and operating agency approvals to Maximus for processing (typically 30-60 days).
• Step 5: POSC Registration: Upon approval, register for the Provider Online Service Center to begin verifying eligibility and submitting claims.

10. Common Denials and Survey Findings

MassHealth and the waiver operating agencies conduct post-payment reviews and periodic audits to ensure compliance. Failure to maintain required documentation or billing errors are the most common reasons for claim denials or recoupments.

Recent policy updates require strict adherence to modifier usage. Billing for a cellular unit without the correct modifier, or failing to secure the updated prescription form, will result in audit findings.

• Missing Modifier U8: Claim denials or recoupments for billing cellular PERS units without the required U8 informational modifier.
• Incomplete Prescription Form: Audit findings for missing or incomplete PERS General Prescription Forms, particularly failing to complete Section 5.
• Lack of Testing Logs: Recoupment of monthly monitoring fees if the provider cannot produce logs showing the unit was actively communicating with the center.
• Plan of Care Mismatch: Claims denied by MMIS because the billed service dates or codes do not match the authorized waiver Plan of Care.
• Expired ASAP Contract: Loss of billing privileges if the provider's subcontract with the regional Aging Services Access Point lapses.

11. Key Contacts and Resources

Providers must navigate multiple state portals and agency contacts to maintain their enrollment and billing status. The primary hub for Medicaid transactions is the MassHealth POSC.

For waiver-specific qualifications, providers must monitor the state's procurement site and utilize the operating agencies' dedicated provider management systems.

• MassHealth Provider Enrollment and Credentialing: Managed by Maximus, reachable at [email protected] for application status (https://www.mass.gov/how-to/apply-to-become-a-masshealth-provider).
• Provider Online Service Center (POSC): The portal for claims submission and eligibility verification (https://newmmis-portal.ehs.state.ma.us/EHSProviderPortal).
• COMMBUYS: The Commonwealth's official procurement record system for finding active DDS and MRC waiver solicitations (https://www.commbuys.com).
• DDS Provider Data Management (PDM): System for DDS waiver provider applications and post-qualification management (https://www.mass.gov/info-details/home-and-community-based-services-hcbs-waivers-for-adults-with-intellectual-disabilities-information-for-providers).
• MassHealth LTSS Provider Portal: Resource for Long-Term Services and Supports provider bulletins and billing guidelines (https://www.masshealthltss.com).

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