Minnesota - Adult Companion Services — Licensing, Medicaid Enrollment and Startup Requirements
Last reviewed: 2026-08-16
In Minnesota, Adult Companion Services provide non-medical care, supervision, and socialization to functionally impaired adults, helping them work toward therapeutic or community integration goals outlined in their support plans. This service is covered under several of Minnesota's Home and Community-Based Services (HCBS) waivers, including the Elderly Waiver (EW), Alternative Care (AC) program, Brain Injury (BI), Community Access for Disability Inclusion (CADI), and Developmental Disabilities (DD) waivers.
The single biggest structural barrier to entry for new providers in Minnesota is the mandatory completion of the HCBS Waiver Provider Training 101 and the steep upfront financial requirement of a $4,200 application fee for a Minnesota Statutes Chapter 245D Basic Support Service license. The state strictly enforces the rule that at least one owner or managerial official must complete the Waiver 101 training before a 245D license application will even be accepted or reviewed by the Department of Human Services (DHS).
1. Service Definition and Scope
Adult Companion Services in Minnesota are defined as non-medical supervision and socialization services that allow an adult to remain safely in the community. These services are designed to reduce isolation, assist with community integration, and support therapeutic goals identified in the participant's coordinated services and support plan (CSSP).
The scope of the service is strictly non-medical. While companions may assist with light meal preparation, hobbies, and social outings, they cannot perform delegated nursing tasks, hands-on personal care assistance (PCA) services, or medical administration that requires a higher level of licensure.
- Covered Waivers: Elderly Waiver (EW), Alternative Care (AC), Brain Injury (BI), Community Access for Disability Inclusion (CADI), and Developmental Disabilities (DD).
- Service Goal: Must directly relate to a therapeutic or community integration goal documented in the person's support plan.
- Excluded Activities: Hands-on medical care, personal care assistance (PCA) tasks, and services provided by the National and Community Services Senior Companion Program.
- Setting Requirements: Services must be delivered in the person's home or in community settings, complying with the federal HCBS Settings Rule.
- Age Requirements: Services are generally targeted at adults aged 18 and older, with specific age criteria dictated by the underlying waiver (e.g., EW is for individuals 65+).
2. Regulatory and Oversight Agencies
The primary regulatory body for Adult Companion Services is the Minnesota Department of Human Services (DHS). DHS oversees the 245D licensing framework, manages the Medicaid waiver programs, and handles provider enrollment. Within DHS, the Licensing Division handles the actual issuance of the 245D license.
Alternatively, providers who already hold a state home care license can apply for an Integrated License with an HCBS Designation through the Minnesota Department of Health (MDH). This allows existing home care agencies to provide basic support services like adult companion care without holding a separate 245D license from DHS.
- Minnesota Department of Human Services (DHS) Licensing Division: Issues and regulates the 245D Basic Support Service license [Minnesota Department of Human Services Licensing Division](https://mn.gov/dhs/partners-and-providers/licensing/hcbs-245d/).
- Minnesota Department of Human Services (DHS) Disability Services Division: Administers the HCBS waiver policies and service standards [Minnesota Department of Human Services Disability Services Division](https://mn.gov/dhs/people-we-serve/people-with-disabilities/services/home-community/).
- Minnesota Department of Health (MDH) Health Regulation Division: Issues the Integrated License with HCBS Designation for existing home care providers [Minnesota Department of Health Health Regulation Division](https://www.health.state.mn.us/facilities/regulation/homecare/index.html).
- Minnesota Health Care Programs (MHCP): The state Medicaid authority responsible for provider enrollment and reimbursement [Minnesota Health Care Programs](https://mn.gov/dhs/partners-and-providers/policies-procedures/minnesota-health-care-programs/).
3. Gatekeeping Prerequisites: Who Can Even Apply
Minnesota does not require a Certificate of Need (CON) or a competitive Request for Proposals (RFP) procurement process to become a 245D-licensed Adult Companion provider. The network is generally open to any willing provider who meets the statutory requirements.
However, there are strict structural prerequisites that block an application from being accepted. The most critical is the HCBS Waiver Provider Training 101; DHS will reject any 245D application if the owner or managerial official has not completed this training. Additionally, applicants must secure a SWIFT Vendor ID from the state and register for the NETStudy 2.0 background check system before applying.
- Waiver Provider Training 101: Mandatory prerequisite training that must be completed by an owner or managerial official before a 245D license application is submitted.
- SWIFT Vendor ID: Applicants must register as a supplier in the Minnesota Supplier Portal to receive a vendor ID, which is required for the MHCP enrollment process.
- NETStudy 2.0 Registration: Providers must establish an account with the DHS background study system to process required staff checks before licensure is finalized.
- Certificate of Need: None exists for this service in Minnesota; the market is open to qualified applicants.
- Network Procurement: None exists for fee-for-service waivers; however, serving EW/AC members often requires subsequent contracting with regional Managed Care Organizations (MCOs).
4. Licensure and Certification Requirements
To provide Adult Companion Services, an agency must obtain a license under Minnesota Statutes Chapter 245D as a Basic Support Service provider. The application process requires submitting a comprehensive pre-application worksheet, organizational charts, and proof of required insurance.
Providers must also submit specific policy templates, including maltreatment reporting and grievance procedures. The application fee is substantial and non-refundable, making it critical that the application is complete and accurate upon submission.
- 245D Basic Support Service License: The statutory license required to provide adult companion services under MN waivers.
- MDH Integrated License Designation: An alternative pathway for agencies already holding an MDH home care license, allowing them to add HCBS basic support services.
- Application Fee: A non-refundable fee of $4,200 must accompany the 245D license application.
- Pre-Application Worksheet: A mandatory DHS form used to assess readiness and organize required documentation prior to submission.
- Designated Manager Verification Form: A required document proving the agency has appointed a qualified individual to oversee program operations.
- Worker's Compensation Form: Verification of required insurance coverage (or exemption) submitted with the application.
5. Medicaid Provider Enrollment
Once the 245D license or MDH Integrated License is secured, the agency must enroll as a provider with Minnesota Health Care Programs (MHCP). This is done entirely online through the Minnesota Provider Screening and Enrollment (MPSE) portal.
For participants on the Elderly Waiver (EW) or Alternative Care (AC) programs enrolled in managed care (MSHO/MSC+), the provider must take an additional step after MHCP enrollment to credential and contract directly with the specific Managed Care Organizations (MCOs) operating in their target counties.
- MPSE Portal: The mandatory online system for submitting MHCP enrollment applications and maintaining provider records [Minnesota Provider Screening and Enrollment Portal](https://mn.gov/dhs/partners-and-providers/policies-procedures/minnesota-health-care-programs/provider/enrollment/mpse/).
- MHCP Provider Agreement: The binding contract signed during MPSE enrollment that dictates compliance with state and federal Medicaid rules.
- MCO Contracting - UCare: Required for serving MSHO/MSC+ members assigned to this plan [UCare Provider Network](https://www.ucare.org/providers).
- MCO Contracting - Blue Plus: Required for serving MSHO/MSC+ members assigned to this plan [Blue Plus Provider Network](https://www.bluecrossmn.com/providers).
- MCO Contracting - Medica: Required for serving MSHO/MSC+ members assigned to this plan [Medica Provider Network](https://www.medica.com/providers).
- MCO Contracting - HealthPartners: Required for serving MSHO/MSC+ members assigned to this plan [HealthPartners Provider Network](https://www.healthpartners.com/provider-public/).
6. Staffing, Training and Background Checks
Under Minn. Stat. 245D.09, agencies must appoint a Designated Coordinator and a Designated Manager. These roles require specific combinations of education and experience in human services. Direct support staff providing the companion services do not need a specific degree but must complete rigorous orientation and annual training.
All staff, volunteers, and controlling individuals must clear a background study through the DHS NETStudy 2.0 system before having direct contact with individuals receiving services. Training is often tracked and delivered via the College of Direct Support (CDS).
- Designated Coordinator Qualifications: Must have a bachelor's degree in a human services field plus one year of full-time work experience providing direct care, or an equivalent combination of education and experience.
- Designated Manager Qualifications: Must meet Designated Coordinator requirements plus have a minimum of three years of supervisory level experience in a program providing direct support services.
- Direct Support Staff Orientation: Must cover person-centered service delivery, maltreatment prevention, mandatory reporting, and emergency procedures before working unsupervised.
- Annual Refresher Training: Ongoing competency-based training required every calendar year for all direct support staff.
- Background Studies: Mandatory fingerprint-based background checks processed through the DHS NETStudy 2.0 system.
7. Documentation, Policies and Records
245D licensed providers are subject to strict documentation and record-keeping standards. Providers must maintain comprehensive personnel files that prove all training and background check requirements have been met for every employee.
Additionally, providers must complete an HCBS Settings Self-Assessment to verify that their service delivery respects the autonomy, privacy, and community integration rights of the participants. Policies must be customized to the agency, not just generic templates.
- HCBS Settings Self-Assessment: Required documentation verifying compliance with the federal HCBS Settings Rule regarding participant rights and community integration.
- Maltreatment Internal Review Policy: A mandatory policy detailing how the agency will internally investigate and report suspected abuse or neglect of vulnerable adults.
- Grievance Policy: A written procedure provided to participants explaining how they can file complaints without fear of retaliation.
- Emergency Procedures: Documented protocols for handling medical emergencies, natural disasters, and other crises.
- Personnel Files: Must contain dates of hire, background study clearance notices, and certificates of completion for all initial and annual trainings.
8. Billing, Rates and Claims
Fee-for-service claims for Adult Companion Services are submitted through MN-ITS, Minnesota's web-based MMIS billing system. Services provided under the BI, CAC, CADI, and DD waivers are reimbursed according to the Disability Waiver Rate System (DWRS), which establishes statewide rate frameworks.
Services provided under the Elderly Waiver (EW) or Alternative Care (AC) programs are subject to different rate limits published annually by DHS. If the participant is enrolled in a managed care plan (MSHO/MSC+), claims must be submitted directly to the MCO rather than through MN-ITS.
- MN-ITS Portal: The state's electronic billing system for fee-for-service Medicaid claims [MN-ITS Portal](https://mn.gov/dhs/partners-and-providers/billing-and-mn-its/).
- Disability Waiver Rate System (DWRS): The framework that dictates reimbursement rates for companion services under the BI, CAC, CADI, and DD waivers.
- Elderly Waiver (EW) Rates: Subject to specific published rate limits that differ from the DWRS framework.
- HCPCS Code: Adult Companion Services are typically billed using HCPCS code T2040.
- Claim Format: Billed using the 837P (Professional) electronic claim format in MN-ITS.
9. Approval Sequence and Timeline
The process to become a fully enrolled Adult Companion provider in Minnesota typically takes 4 to 6 months. The sequence must be followed strictly, as DHS will not process out-of-order applications.
The timeline begins with the mandatory training, followed by the licensure application, background checks, Medicaid enrollment, and finally, managed care contracting if applicable.
- Step 1: Waiver 101 Training: Must be completed by an owner/manager (1-2 weeks to schedule and complete).
- Step 2: 245D Application: Submitted to DHS Licensing Division; statutory review timeframe is up to 90 days.
- Step 3: Background Studies: Initiated via NETStudy 2.0 once the license application is in process (1-3 weeks).
- Step 4: MHCP Enrollment: Submitted via MPSE portal after the 245D license is issued (30-60 days for processing).
- Step 5: MCO Credentialing: Required only if serving managed care populations; initiated after MHCP enrollment (60-90 days).
10. Common Denials and Survey Findings
Applications for a 245D license are frequently delayed or denied due to incomplete documentation or failure to meet the strict prerequisite requirements. DHS Licensing is meticulous about verifying the qualifications of the Designated Manager.
During post-licensure surveys, providers are most commonly cited for failing to maintain up-to-date training records in personnel files or failing to align their service delivery documentation with the participant's coordinated services and support plan (CSSP).
- Missing Waiver 101 Certificate: Application immediately rejected if the certificate of completion is not included.
- Unqualified Designated Manager: Denials occur when the proposed manager lacks the required 3 years of supervisory experience in direct support services.
- Generic Policies: Applications delayed when providers submit blank or uncustomized DHS policy templates.
- Background Study Lapses: Citations issued when staff begin working before receiving official clearance from NETStudy 2.0.
- Training Record Deficiencies: Survey findings commonly cite missing annual refresher training certificates in staff personnel files.
11. Key Contacts and Resources
Navigating the 245D licensure and MHCP enrollment process requires interaction with several state help desks. The DHS Licensing Division is the primary contact for questions regarding the 245D application and statutory compliance.
For questions related to Medicaid billing, the MPSE portal, or fee-for-service claims, providers should contact the MHCP Provider Resource Center.
- DHS Licensing Division: Handles 245D applications and compliance questions [Minnesota Department of Human Services Licensing Division](https://mn.gov/dhs/partners-and-providers/licensing/hcbs-245d/).
- MHCP Provider Resource Center: Assists with MN-ITS billing and general Medicaid policy questions [Minnesota Health Care Programs](https://mn.gov/dhs/partners-and-providers/policies-procedures/minnesota-health-care-programs/).
- MDH Home Care Program: Contact for the Integrated License HCBS Designation [Minnesota Department of Health Health Regulation Division](https://www.health.state.mn.us/facilities/regulation/homecare/index.html).
- MPSE Help Desk: Provides technical support for the online Medicaid enrollment portal [Minnesota Provider Screening and Enrollment Portal](https://mn.gov/dhs/partners-and-providers/policies-procedures/minnesota-health-care-programs/provider/enrollment/mpse/).
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