Nebraska - Personal Assistance Services — Licensing, Medicaid Enrollment and Startup Requirements
Last reviewed: 2026-08-16
In Nebraska, Personal Assistance Services (PAS) provide essential hands-on help with activities of daily living, such as bathing, dressing, transferring, and toileting, allowing aged and disabled individuals to remain in their own homes. These services are funded through Nebraska's Regular State Plan Medicaid and the Aged and Disabled (AD) Waiver, administered by the Department of Health and Human Services (DHHS) Division of Medicaid and Long-Term Care.
The single biggest structural barrier to entry for this service in Nebraska is that the state does not issue a distinct non-medical home care license; instead, market entry hinges entirely on passing a rigorous Medicaid provider enrollment screening through the state's vendor, Maximus, followed by mandatory network contracting with Nebraska's three Heritage Health Managed Care Organizations (MCOs). Without securing active contracts with these MCOs after state enrollment, an agency cannot receive client authorizations or bill for services.
1. Service Definition and Scope
Personal Assistance Services (PAS) in Nebraska are defined as hands-on assistance with Activities of Daily Living (ADLs) and Instrumental Activities of Daily Living (IADLs) provided to individuals in their own homes. The scope of service is strictly governed by Title 471 of the Nebraska Administrative Code (NAC).
Services can be delivered through an agency model or a participant-directed model where the client acts as the employer of an independent provider. Legally responsible relatives, such as spouses, are generally prohibited from being paid caregivers under this program.
- Service Name: Personal Assistance Services (PAS)
- Governing Regulation: Title 471 Nebraska Administrative Code (NAC) Chapter 15
- Target Population: Aged and disabled individuals meeting nursing facility level of care criteria (Title 471 NAC Chapter 12) or State Plan requirements
- Covered Tasks: Hands-on assistance with bathing, dressing, transferring, toileting, eating, and mobility
- Delivery Models: Agency-employed providers and participant-directed independent providers
- Excluded Providers: Legally responsible persons (e.g., spouses) cannot be paid as independent providers
2. Regulatory and Oversight Agencies
The Nebraska Department of Health and Human Services (DHHS) is the primary umbrella agency, with its Division of Medicaid and Long-Term Care (MLTC) directly administering the PAS program. DHHS utilizes a third-party vendor, Maximus, to handle all provider screening and enrollment through the Provider Data Management System (PDMS).
Once enrolled with the state, providers must operate under the oversight of the Heritage Health managed care program, which delegates day-to-day care coordination and claims processing to three contracted Managed Care Organizations (MCOs).
- Oversight Agency: Nebraska Department of Health and Human Services (DHHS) (https://dhhs.ne.gov)
- Medicaid Division: DHHS Division of Medicaid and Long-Term Care (MLTC) (https://dhhs.ne.gov/Pages/Medicaid-and-Long-Term-Care.aspx)
- Enrollment Vendor: Maximus Provider Screening and Enrollment (https://nebraskamedicaidproviderenrollment.com)
- Managed Care Program: Heritage Health (https://dhhs.ne.gov/Pages/Heritage-Health.aspx)
- MCO 1: UnitedHealthcare Community Plan of Nebraska (https://www.uhcprovider.com)
- MCO 2: Molina Healthcare of Nebraska (https://www.molinahealthcare.com/providers/ne/medicaid/home.aspx)
- MCO 3: Nebraska Total Care (https://www.nebraskatotalcare.com/providers.html)
3. Gatekeeping Prerequisites: Who Can Even Apply
Nebraska does not utilize a Certificate of Need (CON) program, Request for Proposals (RFP), or closed network moratoria for Personal Assistance Services. There is no state-level facility licensure prerequisite blocking an application, as Nebraska does not license non-medical home care agencies.
The primary structural precondition is that an applicant must establish a business entity, obtain a Type 2 NPI, and successfully enroll as a Nebraska Medicaid provider before they are permitted to apply for network inclusion with the three Heritage Health MCOs. MCO contracting is a mandatory prerequisite for receiving client referrals and authorizations.
- Facility Need Review / CON: None required for PAS in Nebraska
- RFP/Procurement: None; open enrollment exists for qualified Medicaid providers
- Licensure Prerequisite: None; Nebraska does not issue a distinct non-medical home care license
- MCO Contracting: Required; providers must contract with UnitedHealthcare, Molina, and Nebraska Total Care after state enrollment
- NPI Requirement: Agencies must obtain a Type 2 NPI, and rendering staff must have Type 1 NPIs before applying
- Out-of-State Providers: Must meet all Nebraska screening requirements and be licensed in their home state if applicable
4. Licensure and Certification Requirements
Nebraska does not have a distinct non-medical home care license. Agencies providing only companion, homemaker, or attendant care fall outside the Health Care Facility Licensure Act and are not licensed by the DHHS Licensure Unit. If an agency provides skilled nursing or therapy, they must obtain a Home Health Agency license under 175 NAC 14.
Instead of a facility license, PAS providers achieve certification by signing the Division of Medicaid and Long-Term Care Service Provider Agreement and complying with statutory in-home personal services worker standards. Agencies must also pass a specific DHHS policy and procedure review during enrollment.
- Non-Medical License: None exists in Nebraska for PAS-only agencies
- Skilled Alternative: Home Health Agency license (175 NAC 14) required only if providing skilled nursing/therapy
- Statutory Standards: Must comply with Neb. Rev. Stat. §§ 71-6501 to 71-6504 for in-home personal services workers
- Medicaid Certification: Achieved by signing the Division of Medicaid and Long-Term Care Service Provider Agreement
- Policy Review: Must pass the HCBS and PAS Agency Policy and Procedure Review during the Maximus enrollment process
5. Medicaid Provider Enrollment
Provider enrollment is processed entirely online through the Provider Data Management System (PDMS) operated by Maximus. PAS agencies enroll under the Home and Community-Based Services (HCBS) track, which requires detailed ownership disclosures and adherence to federal screening guidelines.
Agencies must pay the CMS-mandated application fee unless they provide proof of payment to Medicare or another state's Medicaid program for the current year. Providers are subject to revalidation every five years.
- Enrollment Portal: Provider Data Management System (PDMS) via Maximus (https://nebraskamedicaidproviderenrollment.com)
- Application Fee: Required for agency providers (matches current CMS institutional fee, updates annually)
- Risk Category: Screened at Limited, Moderate, or High risk per 42 CFR 455.450
- Required Form: Nebraska Medicaid Provider Application and Service Provider Agreement
- Ownership Disclosure: Must disclose all individuals or entities with 5% or more ownership or control interest
- Revalidation: Required every five years per 42 CFR 455.414
6. Staffing, Training and Background Checks
PAS agencies are strictly responsible for ensuring all direct care staff meet minimum qualifications and pass comprehensive background checks before providing any services. Nebraska law mandates checks against multiple state registries to protect vulnerable adults and children.
Agencies must maintain documented training plans that align with Title 471 NAC Chapter 15, ensuring staff are competent in ADL assistance, infection control, and recognizing signs of abuse or neglect.
- Minimum Age: Caregivers must be at least 19 years old, or 18 if registered as a Certified Nursing Assistant (CNA)
- Registry Checks: Mandatory checks against the Nebraska Child and Adult Abuse and Neglect Registry (https://ecmp.nebraska.gov/DHHS-CR/)
- Criminal Background: State and national criminal history checks required for all direct care staff prior to hire
- Nurse Aide Registry: Must verify worker status on the Nebraska Nurse Aide Registry to ensure no findings of abuse
- Training Requirements: Agency must maintain and submit proof of staff qualifications and ongoing training plans
- Employee Screening: Agencies must screen employees against federal OIG exclusion lists monthly
7. Documentation, Policies and Records
Nebraska DHHS requires PAS agencies to maintain comprehensive administrative, personnel, and client records. During the enrollment phase, agencies must submit specific operational policies for state review, including emergency preparedness and incident reporting protocols.
Client records must clearly document the authorized care plan, daily service logs, and Electronic Visit Verification (EVV) data. All records must be retained and available for state or MCO audit upon request.
- Policy Submission: Must submit operational documents for the HCBS and PAS Agency Policy and Procedure Review
- Client Records: Must maintain detailed care plans, service authorizations, and daily service logs
- Personnel Files: Must contain background check results, training certificates, and I-9 forms
- Retention Period: Records must be kept for a minimum of five years from the date of service
- EVV Compliance: Must maintain policies for Electronic Visit Verification data collection and submission
- Incident Reporting: Must have documented procedures for reporting critical incidents to DHHS and MCOs
8. Billing, Rates and Claims
PAS claims are primarily billed to the client's assigned Heritage Health MCO, or directly to the state MMIS for the small population of fee-for-service clients. Services are typically billed in 15-minute increments according to the DHHS Provider Rate and Fee Schedule.
Nebraska strictly enforces the 21st Century Cures Act mandate for Electronic Visit Verification (EVV). All personal care visits must be logged through an approved EVV system; claims lacking matching EVV data will be automatically denied.
- Billing System: Claims submitted via MCO clearinghouses or the state MMIS portal
- EVV Requirement: Mandatory for all PAS claims; failure to log visits results in immediate claim denial
- MCO Payers: UnitedHealthcare Community Plan, Molina Healthcare, and Nebraska Total Care
- Prior Authorization: Required from the MCO or state for all PAS hours before services commence
- Rate Structure: Paid in 15-minute increments according to the published DHHS Provider Rate and Fee Schedule
- Claim Timely Filing: Generally must be submitted within 180 days of the date of service, subject to specific MCO contracts
9. Approval Sequence and Timeline
Becoming a fully operational PAS agency in Nebraska is a multi-step process that begins with federal NPI registration and ends with MCO contracting. Because there is no state facility license to obtain, the critical path runs directly through Maximus.
State Medicaid enrollment typically takes up to 3 months. Once the state issues an active Medicaid ID, the provider must initiate credentialing and contracting with the three Heritage Health MCOs, which can add an additional 60 to 90 days before the agency can accept clients.
- Step 1: Obtain a Type 2 NPI and prepare agency policies and procedures
- Step 2: Submit application and pay CMS fee via Maximus PDMS (State processing takes up to 3 months)
- Step 3: Pass the DHHS HCBS Policy and Procedure Review
- Step 4: Receive Nebraska Medicaid ID and active enrollment status
- Step 5: Apply for network credentialing with UHC, Molina, and Nebraska Total Care (adds 60-90 days)
- Step 6: Implement EVV system and begin accepting MCO prior authorizations
10. Common Denials and Survey Findings
Enrollment applications are frequently delayed or denied due to incomplete ownership disclosures or failure to pass the HCBS Policy and Procedure Review. Agencies must ensure their submitted policies explicitly address Nebraska's specific PAS regulations.
Post-enrollment, the most common reasons for claim denials and audit clawbacks involve EVV discrepancies and providing services without an active prior authorization. Auditors also frequently cite agencies for missing background checks in personnel files.
- Enrollment Denial: Failure to pay the CMS application fee or provide proof of prior payment
- Policy Rejection: Incomplete or missing HCBS and PAS Agency Policy and Procedure documents during Maximus screening
- Claim Denial: EVV data (location, time in/out) does not match the billed hours
- Claim Denial: Providing services before MCO prior authorization is officially approved and active
- Audit Finding: Missing or expired background check documentation in personnel files prior to the first date of service
- Audit Finding: Billing for tasks not explicitly authorized in the client's approved care plan
11. Key Contacts and Resources
Providers should rely on the Maximus portal for all enrollment and revalidation tasks, and maintain close contact with the provider relations departments of the three Heritage Health MCOs for billing and authorization issues.
The DHHS website hosts the official regulations (Title 471 NAC), fee schedules, and access to the mandatory abuse registries.
- Maximus Provider Enrollment: 844-374-5022 or https://nebraskamedicaidproviderenrollment.com
- DHHS MLTC Division: https://dhhs.ne.gov/Pages/Medicaid-and-Long-Term-Care.aspx
- Nebraska Total Care (MCO): 1-844-385-2192 or https://www.nebraskatotalcare.com/providers.html
- UnitedHealthcare Community Plan (MCO): 1-866-331-2243 or https://www.uhcprovider.com
- Molina Healthcare of Nebraska (MCO): https://www.molinahealthcare.com/providers/ne/medicaid/home.aspx
- Child/Adult Abuse & Neglect Registry: https://ecmp.nebraska.gov/DHHS-CR/
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