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

Last reviewed: 2026-09-10

The Minnesota Department of Human Services (DHS) funds Personal Emergency Response Systems (PERS) through the Brain Injury (BI), Community Alternative Care (CAC), Community Access for Disability Inclusion (CADI), Developmental Disabilities (DD), and Elderly Waiver (EW) programs. Providers must meet the specific provider standards and qualifications for 24-hour emergency assistance outlined in the Community-Based Services Manual (CBSM) to be authorized by lead agencies to deliver this service.

Approval requires direct enrollment with Minnesota Health Care Programs (MHCP) as a waiver service provider, which mandates compliance with state plan service standards. The structural precondition for applicants is the requirement to maintain an active MHCP enrollment and demonstrate the infrastructure to provide continuous 24-hour, 7-day-a-week response capabilities before a county, tribal nation, or managed care organization will authorize a service agreement.

1. Service Definition and Scope

PERS in Minnesota is defined as electronic devices that enable individuals to secure help in an emergency, supporting those who live alone or are at risk of falls to remain in the community. The service encompasses the equipment, installation, monthly monitoring, and ongoing maintenance.

The service is designed to increase independence and community integration, and must be documented in the participant's Person-Centered Plan (PCP).

• Covered Waivers: Brain Injury (BI), Community Alternative Care (CAC), Community Access for Disability Inclusion (CADI), Developmental Disabilities (DD), and Elderly Waiver (EW).
• Equipment Types: Wearable devices (such as pendants or bracelets) and installed base units.
• Response Requirement: Providers must ensure response to device signals 24 hours per day, 7 days per week.
• Maintenance: Providers must replace malfunctioning devices within 24 hours of notification.
• Testing: Requires monthly testing of the PERS device to ensure functionality.
• Limitations: Cannot be used by a participant who lives in a provider-owned or controlled setting unless there is a transition plan to move to an independent setting within six months.

2. Regulatory and Oversight Agencies

The Minnesota Department of Human Services (DHS) oversees the administration of HCBS waivers and provider enrollment. Lead agencies, which include counties, tribal nations, and managed care organizations (MCOs), handle individual service authorizations and care planning.

Providers interact primarily with the DHS Provider Eligibility and Compliance division for enrollment and with local lead agencies for service agreements.

• Minnesota Department of Human Services (DHS): https://mn.gov/dhs
• DHS Disability Services Division (DSD): https://mn.gov/dhs/people-we-serve/people-with-disabilities/services/home-community/
• Minnesota Health Care Programs (MHCP) Provider Enrollment: https://mn.gov/dhs/partners-and-providers/enroll-with-mhcp/
• Minnesota Provider Screening and Enrollment (MPSE) Portal: https://mn.gov/dhs/partners-and-providers/enroll-with-mhcp/mpse/

3. Gatekeeping Prerequisites: Who Can Even Apply

Minnesota does not impose a Certificate of Need, competitive procurement (RFP), or closed network moratorium on PERS providers. However, applicants must meet specific structural preconditions to be eligible for MHCP enrollment and service authorization.

Providers must establish their business and operational capacity before applying, as lead agencies will not issue service agreements to unapproved vendors.

• MHCP Enrollment: Must be an actively enrolled Minnesota Health Care Programs provider.
• 24-Hour Capacity: Must demonstrate the infrastructure to provide or subcontract 24-hour emergency assistance response.
• Lead Agency Authorization: Cannot bill for services without a prior service agreement authorized by a county, tribal nation, or MCO lead agency.
• State Plan Compliance: Providers of health services must enroll as a provider of one or more state plan services and meet applicable standards.
• No Self-Direction: PERS cannot be self-directed or provided by a relative or legally responsible individual.

4. Licensure and Certification Requirements

Minnesota does not issue a distinct facility or agency license (such as a 245D license) specifically for standalone PERS equipment vendors. Instead, providers are approved through the MHCP enrollment process.

Approval is granted by attesting to and meeting the standards for 24-hour emergency assistance outlined in the Community-Based Services Manual (CBSM).

• Licensure Exemption: No specific DHS 245D license is required for standalone PERS equipment and monitoring.
• CBSM Standards: Must meet the provider standards and qualifications for 24-hour emergency assistance for BI, CAC, CADI, and DD waivers.
• Business Registration: Must be registered and in good standing with the Minnesota Secretary of State.
• Federal Registration: Must obtain a National Provider Identifier (NPI) if functioning as a healthcare provider, or a Unique Minnesota Provider Identifier (UMPI) if atypical.

5. Medicaid Provider Enrollment

Prospective PERS providers must enroll through the Minnesota Provider Screening and Enrollment (MPSE) portal. The process involves submitting organizational details, ownership information, and signing the MHCP Provider Agreement.

Providers must maintain their enrollment status and update any changes in ownership or contact information through the portal.

• Enrollment System: Minnesota Provider Screening and Enrollment (MPSE) portal.
• Provider Type: Must select the appropriate HCBS waiver provider type and PERS specialty during enrollment.
• Application Fee: Subject to the federal Medicaid/Medicare institutional provider application fee unless waived or already paid to Medicare.
• Required Form: DHS-4138 (MHCP Provider Agreement).
• Revalidation: Must revalidate enrollment every five years through the MPSE portal.

6. Staffing, Training and Background Checks

While PERS is primarily an equipment and monitoring service, any staff interacting directly with waiver participants or handling their protected health information must meet state background study and training requirements.

Agencies must ensure that installation technicians and response center staff are properly trained.

• Background Studies: Direct contact staff must clear a Minnesota Department of Human Services NETStudy 2.0 background check.
• Instructional Staff: Personnel delivering and installing devices must be trained to provide instruction to the participant on device usage.
• Responder Updates: Staff must update the list of responders and contact names for each participant at least twice a year.
• Universal Precautions: Staff entering homes must be trained in and utilize universal precautions.

7. Documentation, Policies and Records

Providers must maintain comprehensive records for each participant to verify service delivery and justify Medicaid billing. Documentation must align with the participant's Person-Centered Plan (PCP) developed by the lead agency.

Records must be made available to DHS or lead agencies upon request for auditing purposes.

• Delivery Verification: Must obtain the participant's or authorized representative's signature verifying receipt of the PERS unit.
• Testing Logs: Must maintain documentation of monthly testing of the PERS device.
• Maintenance Records: Must document any malfunctions and the replacement of devices within the required 24-hour window.
• Data Privacy: Must maintain policies complying with the Minnesota Government Data Practices Act and HIPAA.

8. Billing, Rates and Claims

PERS services are billed to MHCP using the Medicaid Management Information System (MMIS) or through the respective Managed Care Organization's claims system. Rates are established by DHS.

Billing is typically divided into a one-time installation component and an ongoing monthly monitoring component.

• Claims System: Fee-for-service claims are processed through the state's Medicaid Management Information System (MMIS) via MN-ITS.
• Rate Structure: Reimbursed as a one-time installation fee and a monthly rental/monitoring fee.
• Public Rate Parity: A vendor cannot charge Medicaid more than they would charge the general public for the same service.
• Service Agreements: Claims will deny if they do not match the exact dates, codes, and units on the lead agency's approved Service Agreement.
• MCO Billing: For participants enrolled in managed care, claims must be submitted directly to the MCO according to their specific fee schedules and rules.

9. Approval Sequence and Timeline

The approval process begins with business registration and culminates in MHCP enrollment and lead agency contracting. Timelines vary based on the completeness of the MPSE application.

Providers cannot begin billing until the MHCP enrollment is fully approved and a lead agency has issued a service agreement.

• Step 1: Register the business entity with the Minnesota Secretary of State.
• Step 2: Obtain an NPI or UMPI.
• Step 3: Submit the provider enrollment application and pay the fee via the MPSE portal.
• Step 4: DHS Provider Eligibility and Compliance reviews the application (typically 30-60 days).
• Step 5: Receive the MHCP Welcome Letter and MN-ITS registration information.
• Step 6: Contract with individual lead agencies (counties/MCOs) to receive service authorizations.

10. Common Denials and Survey Findings

Enrollment applications and claims are frequently delayed or denied due to administrative errors or failure to meet specific waiver criteria.

DHS and lead agencies conduct audits to ensure compliance with service standards and documentation requirements.

• Enrollment Denial: Failure to pay the required application fee or provide proof of Medicare payment.
• Claim Denial: Billing for dates of service before the lead agency officially approved the Service Agreement.
• Audit Finding: Missing participant signatures verifying the initial receipt and installation of the PERS unit.
• Audit Finding: Lack of documentation proving that monthly system performance checks and testing were completed.
• Setting Limitation: Authorizing PERS for a participant living in a provider-controlled setting without a documented transition plan.

11. Key Contacts and Resources

Providers should utilize official DHS manuals and contact centers for guidance on enrollment, billing, and policy updates.

The Community-Based Services Manual (CBSM) is the primary policy resource for waiver service standards in Minnesota.

• MHCP Provider Resource Center: https://mn.gov/dhs/partners-and-providers/contact-us/minnesota-health-care-programs/providers/index.jsp
• Community-Based Services Manual (CBSM): https://www.dhs.state.mn.us/id_000402
• Minnesota Provider Screening and Enrollment (MPSE) Portal: https://mn.gov/dhs/partners-and-providers/enroll-with-mhcp/mpse/
• MN-ITS (Billing Portal): https://mn.gov/dhs/partners-and-providers/policies-procedures/minnesota-health-care-programs/provider/mn-its/

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