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Nebraska - Skilled Nursing Services — Licensing, Medicaid Enrollment and Startup Requirements

Last reviewed: 2026-09-10

Nebraska DHHS Division of Public Health licenses the delivery of in-home RN and LPN care under Title 175 NAC 14 as a Home Health Agency, which serves as the foundational requirement to bill Skilled Nursing Services under the state's Aged and Disabled (AD) and Traumatic Brain Injury (TBI) waivers. Because Nebraska does not issue a standalone "Skilled Nursing" license for HCBS providers, agencies must meet the full structural and clinical requirements of a licensed Home Health Agency before applying to deliver waiver-funded nursing.

Approval requires securing the HHA license, obtaining a mandatory referral from a regional Resource Developer (RD) worker, and completing the Form MC-19 Service Provider Agreement through the Maximus enrollment portal. The mandatory RD worker referral blocks any direct Medicaid enrollment application until regional need or client assignment is established by the state.

1. Service Definition and Scope

Skilled Nursing Services in Nebraska HCBS waivers consist of nursing interventions delivered in the participant's home by a licensed RN or LPN. These services must be ordered by a physician and included in a formal plan of care.

The scope includes comprehensive assessment, medication administration, and skilled treatments that exceed the scope of personal care or home health aide services, requiring the clinical judgment of a licensed nurse.

2. Regulatory and Oversight Agencies

The Nebraska Department of Health and Human Services (DHHS) divides oversight between its public health and Medicaid divisions. The Division of Public Health handles the facility licensure required to operate, while the Division of Medicaid and Long-Term Care (MLTC) manages waiver policy.

Provider enrollment and screening are outsourced to Maximus, which operates the state's provider portal and processes the Form MC-19 agreements.

3. Gatekeeping Prerequisites: Who Can Even Apply

Nebraska does not require a Certificate of Need (CON) or Facility Need Review (FNR) to open a Home Health Agency. Any legally formed entity may apply for the base HHA license if they meet the clinical and administrative standards of Title 175 NAC 14.

However, to enroll as a Medicaid HCBS waiver provider, agencies face a strict referral gate. A provider cannot simply create a Maximus account and enroll; they must first receive a provider referral from a regional Resource Developer (RD) worker.

4. Licensure and Certification Requirements

To provide Skilled Nursing Services, the agency must be licensed as a Home Health Agency under Title 175 NAC 14. The agency must be primarily engaged in providing skilled nursing care or a minimum of one other therapeutic service.

Nebraska accepts deemed status from recognized national accrediting bodies in lieu of standard state inspections for certain compliance elements, provided the agency maintains its accreditation.

5. Medicaid Provider Enrollment

Once licensed and referred by an RD worker, the agency enrolls through the Maximus web portal. The core enrollment document is the Nebraska Service Provider Agreement (Form MC-19).

Agencies must enroll each physical location separately and provide their National Provider Identifier (NPI) and Federal Tax Identification Number (FTIN) along with a W-9.

6. Staffing, Training and Background Checks

Direct care must be delivered by Registered Nurses (RNs) or Licensed Practical Nurses (LPNs) holding active, unencumbered licenses from the Nebraska Board of Nursing.

The agency must maintain a supervising RN who oversees the clinical practice of all LPNs and ensures care aligns with the physician-approved plan of care.

7. Documentation, Policies and Records

Agencies must maintain comprehensive clinical records for every participant, anchored by a physician-ordered plan of care. This plan must be established after an initial visit by a qualified professional.

Administrative policies must include bylaws or equivalent rules governing the agency's operation, as well as written contracts for any services provided by arrangement.

8. Billing, Rates and Claims

Claims for Skilled Nursing Services are submitted through the Nebraska Medicaid MMIS. Providers must use the specific procedure codes authorized in their waiver service authorization.

Rates are established by the DHHS Division of Medicaid and Long-Term Care and are published in the Medicaid fee schedules. Payment is only made for services explicitly detailed in the approved plan of care.

9. Approval Sequence and Timeline

The critical path begins with entity formation and applying for the Home Health Agency license through the Division of Public Health. Only after licensure can the agency seek the necessary RD worker referral.

Once the RD worker submits the referral to Maximus, the provider creates an account, submits Form MC-19, and undergoes background and credential screening before receiving a Medicaid provider number.

10. Common Denials and Survey Findings

Licensure applications are frequently delayed due to incomplete policies, missing bylaws, or failure to designate a qualified supervising RN available during all operating hours.

During surveys, the most common citations involve clinical documentation, specifically the failure to have the plan of care reviewed and signed by the physician and RN every 62 days as required by Title 175 NAC 14.

11. Key Contacts and Resources

Providers should rely on the DHHS Division of Public Health for licensure regulations and the Maximus portal for enrollment instructions. The Nebraska Medicaid Provider Handbook contains specific billing and service limitations.

Regional Resource Developers are the primary point of contact for initiating the waiver enrollment process once licensed.

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