Minnesota - Day Habilitation Services — Licensing, Medicaid Enrollment and Startup Requirements
Last reviewed: 2026-09-10
The Minnesota Department of Human Services (DHS) licenses Day Training and Habilitation (DT&H) under Minnesota Statutes, Chapter 245D as an intensive support service funded primarily through the Developmental Disabilities (DD) waiver. DT&H provides structured daytime programming to adults 18 and older with developmental disabilities to build self-help, socialization, and adaptive skills outside their residence.
Effective January 1, 2026, DHS implemented a temporary 245D licensing moratorium, halting all new applications and service line additions through December 31, 2027, unless a specific lead agency exception is granted. Providers navigating this exception process must secure a National Provider Identifier (NPI) for each location, pass DHS background studies, and enroll through the Minnesota Provider Screening and Enrollment (MPSE) portal.
1. Service Definition and Scope
In Minnesota, Day Habilitation is officially termed Day Training and Habilitation (DT&H) or simply Day Services under the state's waiver programs. These services assist individuals in developing and maintaining life skills, participating in community life, and engaging in proactive therapeutic activities.
DT&H services can be facility-based or community-based and are authorized based on a person-centered community support plan. The service is distinct from prevocational services and supported employment, focusing instead on broader adaptive and socialization goals.
- Target Population: Adults 18 or older with a diagnosis of developmental disability or a related condition.
- Funding Authority: Primarily the Developmental Disabilities (DD) waiver, but day services are also defined under BI, CAC, and CADI waivers.
- Service Duration: Defined as full day (6 or more hours) or partial day (less than 6 hours).
- Location Requirement: Must be provided outside the individual's residence.
- Transportation: Can be billed separately or included depending on the authorization and delivery model.
2. Regulatory and Oversight Agencies
The Minnesota Department of Human Services (DHS) is the primary regulatory body for HCBS waivers and 245D licensure. DHS Licensing oversees compliance with health and safety standards, while the Provider Eligibility and Compliance division manages Medicaid enrollment.
County and tribal human services offices act as lead agencies. They conduct needs assessments, authorize services, and are the entities that must request exceptions to the current licensing moratorium on behalf of a provider.
- Licensing Agency: DHS Licensing Division (https://www.dhs.state.mn.us/Licensing)
- Enrollment Agency: DHS Provider Eligibility and Compliance (https://mn.gov/dhs/partners-and-providers/enroll-with-mhcp/)
- Local Oversight: County or Tribal Lead Agencies (https://mn.gov/dhs/people-we-serve/adults/health-care/health-care-programs/contact-us/county-tribal-offices.jsp)
- Enrollment System: Minnesota Provider Screening and Enrollment (MPSE) portal (https://mn.gov/dhs/partners-and-providers/policies-procedures/minnesota-health-care-programs/provider/mpse/)
3. Gatekeeping Prerequisites: Who Can Even Apply
Minnesota currently enforces a strict statutory moratorium on new 245D licenses. Without a formal exception initiated by a county or tribal lead agency demonstrating critical need, DHS will automatically cancel any submitted application.
Additionally, providers must establish formal agreements with local entities before delivering services. Satellite locations cannot operate under a single umbrella identifier; each physical site must be independently enumerated.
- 245D Licensing Moratorium: Active from January 1, 2026, through December 31, 2027; blocks all new applications and service line additions.
- Lead Agency Exception: The absolute prerequisite to bypass the moratorium; must be requested by a county or tribal agency based on access needs.
- Three-Party Agreement: Required annually between the training and habilitation agency, the ICF/DD (if applicable), and the county.
- Site Enumeration: Each DT&H satellite location must obtain its own unique National Provider Identifier (NPI) or Unique Minnesota Provider Identifier (UMPI).
4. Licensure and Certification Requirements
DT&H providers must hold a 245D Intensive Support Services license. This licensure ensures providers meet rigorous standards for health, safety, and person-centered planning.
If a provider is granted a moratorium exception, they must submit a comprehensive application detailing their policies, procedures, and physical site compliance. The application requires a non-refundable fee, though fees for applications canceled by the moratorium are refunded.
- Statutory Authority: Minnesota Statutes, Chapter 245D.
- License Category: Intensive Support Services.
- Application Fee: $500 submitted with the 245D application.
- Required Form: HCBS Programs Service Request Form (DHS-6638).
- Insurance Requirement: General liability insurance certificate naming "DHS Provider Eligibility and Compliance" as a certificate holder.
5. Medicaid Provider Enrollment
After obtaining a 245D license, providers must enroll in Minnesota Health Care Programs (MHCP). Enrollment is processed entirely online through the MPSE portal, which requires a MN-ITS account.
Providers are screened against federal and state exclusion lists. Depending on the provider's exact structure and Medicare enrollment status, an application fee may be required during the MHCP enrollment phase.
- Enrollment Portal: Minnesota Provider Screening and Enrollment (MPSE) portal.
- Billing System: MN-ITS registration is required upon approval.
- Exclusion Checks: Mandatory screening against the HHS Office of Inspector General (OIG) and state excluded provider lists.
- Application Fee: Federal Medicaid application fee may apply for newly enrolling or revalidating providers.
- Effective Date: May be approved retroactively up to the first day of the month the application was received, or up to 90 days prior if criteria are met.
6. Staffing, Training and Background Checks
Minnesota requires all direct care staff and managers to pass a background study before having direct contact with individuals receiving services. These studies are processed through the state's NETStudy 2.0 system.
Staff must complete basic 245D orientation and training within 60 days of hire. This includes training on vulnerable adult maltreatment reporting, person-centered planning, and the specific needs of the individuals they support.
- Background Studies: Mandatory clearance through DHS NETStudy 2.0.
- Orientation Timeline: Basic 245D training must be completed within 60 days of hire.
- Maltreatment Training: Required instruction on reporting maltreatment of vulnerable adults.
- First Aid/CPR: Direct support professionals must maintain current certification.
7. Documentation, Policies and Records
245D licensed providers must maintain a comprehensive policy and procedure manual. This includes protocols for incident reporting, grievance procedures, and emergency response.
Providers are also subject to annual reporting requirements and must maintain detailed service records to support all claims billed to MHCP. Services cannot be billed without an active Service Authorization (SA) in the MMIS system.
- Annual Report: Day service providers must submit an annual report to DHS by March 1 of each year.
- Service Authorization (SA): Must be entered into the DHS MMIS system by the case manager before services are provided.
- Self-Monitoring: Providers must use DHS sample self-monitoring checklists to ensure ongoing 245D compliance.
- Record Retention: Must maintain records sufficient to justify all billed units and demonstrate compliance with the person's support plan.
8. Billing, Rates and Claims
Rates for DT&H services under HCBS waivers are determined by the Disability Waiver Rates Management System (DWRS). The lead agency uses DWRS to establish individual rates based on the person's assessed needs.
Providers bill MHCP using specific HCPCS codes and modifiers to distinguish between full days, partial days, and transportation. Claims must be submitted with the most current diagnosis code.
- Rate Setting: Disability Waiver Rates Management System (DWRS).
- Full Day Code: T2020 (6 or more hours of service).
- Partial Day Code: T2020 with modifier U5 (less than 6 hours of service).
- Transportation Code: T2002 (billed separately if authorized).
- Claim Frequency: Bill only one calendar month on each claim submission, with each date on a separate line.
9. Approval Sequence and Timeline
The approval process is currently dictated by the moratorium exception workflow. A provider cannot begin the licensure process until a lead agency successfully petitions DHS for an exception.
Once an exception is granted, the provider submits the 245D application, obtains site-specific NPIs, and completes MPSE enrollment. The entire process can take several months depending on background study processing and site inspections.
- Step 1: Secure a lead agency exception to the 245D moratorium.
- Step 2: Submit the 245D Intensive Support Services license application and $500 fee.
- Step 3: Obtain a unique NPI for each physical DT&H location.
- Step 4: Submit the MHCP enrollment application via the MPSE portal.
- Step 5: Register for MN-ITS upon receipt of the welcome letter.
10. Common Denials and Survey Findings
The most frequent cause for application denial is submitting a 245D application during the moratorium without an approved lead agency exception. These applications are automatically canceled.
During surveys or claims audits, providers frequently face recoupments for billing without a valid Service Authorization, failing to enumerate satellite sites properly, or allowing staff to work before NETStudy 2.0 clearance is finalized.
- Moratorium Cancellation: Automatic rejection of 245D applications lacking a lead agency exception.
- NPI Errors: Using a single NPI for multiple satellite locations instead of enumerating each site.
- Authorization Mismatch: Billing for dates, units, or codes not explicitly listed on the MMIS Service Authorization.
- Background Study Violations: Permitting staff to provide direct contact services before receiving official DHS clearance.
11. Key Contacts and Resources
DHS provides several dedicated help desks and online manuals to assist providers with licensure and enrollment. The Community-Based Services Manual (CBSM) is the definitive guide for waiver service policies.
Providers should regularly check the MHCP provider news and updates page for changes to billing codes, DWRS rate adjustments, and moratorium exception procedures.
- DHS Licensing Help Desk: 651-431-6624 (Monday-Friday, 8:00 am - 4:00 pm).
- DHS Licensing Website: https://www.dhs.state.mn.us/Licensing
- MPSE Portal: https://mn.gov/dhs/partners-and-providers/policies-procedures/minnesota-health-care-programs/provider/mpse/
- MHCP Provider News: https://mn.gov/dhs/partners-and-providers/news-initiatives-reports-workgroups/minnesota-health-care-programs/provider-news/index.jsp
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