Michigan - Adult Companion Services — Licensing, Medicaid Enrollment and Startup Requirements
Last reviewed: 2026-09-10
The Michigan Department of Health and Human Services (MDHHS) does not cover or license a distinct service named Adult Companion Services, instead funding non-medical supervision and socialization through Community Living Supports (CLS) under the MI Choice and Habilitation Supports (HSW) 1915(c) waivers. Providers delivering these services operate as atypical Medicaid providers delivering CLS to ensure individuals remain safely in their homes and communities.
Approval to bill for these services requires an applicant to secure a direct subcontract with a regional MI Choice Waiver Agency or a Prepaid Inpatient Health Plan (PIHP) before submitting an enrollment application. Without an active contract from one of these regional designating entities, an agency cannot receive authorizations or reimbursement through the Community Health Automated Medicaid Processing System (CHAMPS).
1. Service Definition and Scope
Because Michigan does not use the Adult Companion Services billing category, providers deliver these supports under the Community Living Supports (CLS) definition. CLS encompasses non-medical supervision, socialization, and assistance with activities of daily living.
The service is designed to prevent institutionalization by providing a trained worker to prompt, cue, or supervise the participant in their unlicensed private residence.
- Service Name: Community Living Supports (CLS)
- Covered Tasks: Socialization, supervision, prompting for activities of daily living, and light incidental assistance
- Excluded Tasks: Skilled nursing care, medication administration, and continuous heavy chore services
- Setting Limitations: Must be delivered in the participant's private home or community, not in a licensed Adult Foster Care (AFC) facility
2. Regulatory and Oversight Agencies
MDHHS sets the overarching policy, waiver definitions, and Medicaid enrollment rules for all HCBS providers in the state. Regional entities handle the actual contracting, credentialing, and daily oversight of CLS providers.
Providers must interact with both the state Medicaid system for baseline enrollment and their regional agency for service authorizations.
- State Agency: Michigan Department of Health and Human Services (MDHHS) (https://www.michigan.gov/mdhhs)
- Division: Behavioral and Physical Health and Aging Services Administration (BPHASA) (https://www.michigan.gov/mdhhs/inside-mdhhs/bphasa)
- Regional Entities (Aging): MI Choice Waiver Agencies / Area Agencies on Aging (https://www.michigan.gov/mdhhs/assistance-programs/medicaid/portalhome/medicaid-providers/programs/mi-choice-waiver-program)
- Regional Entities (Behavioral Health): Prepaid Inpatient Health Plans (PIHPs) (https://www.michigan.gov/mdhhs/keep-mi-healthy/mentalhealth/mentalhealth/pihp)
3. Gatekeeping Prerequisites: Who Can Even Apply
Michigan utilizes a closed-network model for waiver services, meaning MDHHS does not accept open, standalone applications for CLS providers to bill the state directly. An agency must be selected by a regional waiver entity.
These regional entities procure providers based on local network adequacy needs, often utilizing specific Request for Proposal (RFP) windows or closed networks.
- Regional Contract Requirement: Applicants must obtain a contract or letter of agreement from a MI Choice Waiver Agency or PIHP
- Procurement Windows: Many regional agencies only accept new provider applications during scheduled RFP periods or when a specific geographic shortage is identified
- Business Registration: Must be registered and in good standing with the Michigan Department of Licensing and Regulatory Affairs (LARA)
- Medicaid Standing: Must not be excluded from federal healthcare programs or the Michigan Medicaid program
4. Licensure and Certification Requirements
Michigan does not issue a specific state facility or agency license for non-medical in-home CLS or companion providers. Instead, providers are certified through the regional waiver agency's credentialing process.
Providers must demonstrate compliance with the MDHHS Minimum Operating Standards for MI Choice Waiver Program Services and the federal HCBS Final Rule.
- State Licensure: None required for non-medical CLS/companion agencies
- Operating Standards: Must meet the MI Choice Contract Attachment H Minimum Operating Standards
- HCBS Final Rule: Settings and policies must comply with federal community integration mandates
- Insurance: Must maintain general liability, professional liability, and workers compensation insurance as dictated by the regional contract
5. Medicaid Provider Enrollment
All providers serving Michigan Medicaid beneficiaries must enroll in the Community Health Automated Medicaid Processing System (CHAMPS). CLS providers typically enroll as atypical providers.
Enrollment in CHAMPS is a screening mechanism; it does not guarantee payment without the corresponding regional waiver agency contract.
- Enrollment Portal: CHAMPS (https://milogintp.michigan.gov)
- Provider Type: Atypical Agency (unless holding professional licensure requiring a Type 2 NPI)
- Application Fee: Atypical providers are generally exempt from the federal Medicaid application fee
- Screening Risk Level: Typically categorized as limited or moderate risk depending on exact ownership structures
6. Staffing, Training and Background Checks
Direct care workers providing CLS must meet baseline qualifications established by MDHHS and verified by the employing agency. Agencies must maintain personnel files proving compliance.
Background checks are mandatory and must be completed before a worker has direct contact with a waiver participant.
- Age Requirement: Direct care workers must be at least 18 years of age
- Background Check: Must complete a criminal history check through the Michigan Workforce Background Check system
- Basic Training: Must complete training in recipient rights, infection control, and emergency procedures
- Participant-Specific Training: Must be trained on the individual's specific person-centered service plan before delivering care
7. Documentation, Policies and Records
Agencies must maintain comprehensive records to survive audits from both MDHHS and their contracting regional agencies. Documentation must prove that services were delivered exactly as authorized.
Michigan is implementing Electronic Visit Verification (EVV) for personal care and related in-home services, which impacts how CLS time is tracked.
- Service Documentation: Must record date, start time, end time, and specific tasks performed for every shift
- EVV Compliance: Must utilize a state-approved Electronic Visit Verification system for applicable in-home shifts
- Incident Reporting: Must have policies to report critical incidents to the waiver agency within 24 hours
- Record Retention: Must retain all clinical and billing records for a minimum of seven years
8. Billing, Rates and Claims
CLS providers do not bill MDHHS directly through CHAMPS for waiver services. Instead, they submit claims or invoices to their contracting MI Choice Waiver Agency or PIHP.
Rates are established by the regional entities within parameters set by MDHHS, meaning reimbursement can vary by county or region.
- Billing System: Claims are submitted to the regional waiver agency's specific clearinghouse or portal
- Procedure Code: Typically billed under H2015 (Community Living Supports) in 15-minute increments
- Rate Setting: Negotiated with or set by the regional waiver agency, not a universal state fee schedule
- Prior Authorization: 100% of billed hours must be prior-authorized in the participant's care plan
9. Approval Sequence and Timeline
The timeline to become a billable provider depends entirely on the procurement schedule of the local waiver agency. If a network is closed, an agency cannot proceed.
Once a contract is offered, the CHAMPS enrollment and credentialing process typically takes several weeks to finalize.
- Step 1: Identify the local MI Choice Waiver Agency or PIHP and verify network status
- Step 2: Submit a proposal or application to the regional entity during an open procurement window
- Step 3: Upon conditional approval, complete atypical provider enrollment in CHAMPS
- Step 4: Finalize the subcontract, complete EVV onboarding, and begin receiving authorizations
10. Common Denials and Survey Findings
New applicants are most frequently denied because they attempt to enroll in CHAMPS without first securing a regional contract. Auditors frequently cite established providers for documentation failures.
Failure to maintain strict background check compliance is a severe finding that results in immediate recoupment of funds.
- Denial Reason: Applying to CHAMPS without a regional waiver agency contract
- Survey Finding: Missing or incomplete timesheets that do not match billed hours
- Survey Finding: Allowing staff to work before the background check clears
- Survey Finding: Delivering services outside the scope of the authorized person-centered service plan
11. Key Contacts and Resources
Providers must rely on MDHHS for systemic rules and CHAMPS support, but must contact their local waiver agencies for contracting and rate information.
The MDHHS Medicaid Provider Manual is the definitive source for all coverage rules.
- MDHHS Provider Enrollment: 1-800-292-2550 (https://www.michigan.gov/mdhhs/doing-business/providers/providers/medicaid/provider-enrollment)
- CHAMPS Portal: (https://milogintp.michigan.gov)
- MI Choice Waiver Program: (https://www.michigan.gov/mdhhs/assistance-programs/medicaid/portalhome/medicaid-providers/programs/mi-choice-waiver-program)
- Michigan Medicaid Provider Manual: (https://www.mdch.state.mi.us/dch-medicaid/manuals/MedicaidProviderManual.pdf)
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