New Hampshire - Adult Companion Services — Licensing, Medicaid Enrollment and Startup Requirements
Last reviewed: 2026-08-16
New Hampshire Medicaid does not recognize "Adult Companion Services" as a standalone waiver service category. Instead, the non-medical supervision and socialization functions that allow an adult to remain safely in the community are licensed and billed as Non-Medical Home Care (Homemaker or Personal Care) under the Choices for Independence (CFI) waiver, or as In-Home Supports under the Developmental Disabilities (DD) and Acquired Brain Disorders (ABD) waivers.
The single biggest structural barrier to entry depends on the target population you intend to serve. For the CFI waiver, providers face a mandatory managed care gate: they must secure credentialing and contracts with New Hampshire's three Medicaid Care Management (MCM) health plans after state enrollment. For the DD/ABD waivers, the state operates a closed network where providers cannot enroll independently; they must be approved by and subcontracted under one of the state's 10 designated regional Area Agencies.
1. Service Definition and Scope
Because New Hampshire does not use a distinct "Adult Companion" service definition, providers must operate under the closest applicable service categories. For older adults and those with physical disabilities, this falls under Homemaker or Personal Care services, which include supervision, socialization, and assistance with activities of daily living.
For individuals with developmental disabilities or acquired brain disorders, companion-like functions are delivered as In-Home Supports or Community Participation Services. Across all these categories, the core scope remains non-medical, focusing on safety monitoring and community integration rather than clinical care.
- Service Equivalent (CFI Waiver): Homemaker and Personal Care Services.
- Service Equivalent (DD/ABD Waivers): In-Home Supports and Community Participation Services.
- Scope of Practice: Non-medical care, supervision, socialization, meal preparation, and light housekeeping.
- Exclusions: Hands-on nursing care, medication administration (unless specifically certified and delegated), and medical treatments.
- Target Population (CFI): Seniors and adults with chronic illnesses at risk of nursing facility placement.
- Target Population (DD/ABD): Adults with developmental disabilities or acquired brain disorders.
2. Regulatory and Oversight Agencies
The New Hampshire Department of Health and Human Services (NH DHHS) is the umbrella agency overseeing all Medicaid and licensing functions. Within DHHS, responsibilities are divided between licensing bodies and specific waiver management bureaus.
Licensure is handled by the Health Facilities Administration (HFA), while the programmatic rules and waiver operations are managed by the Bureau of Elderly and Adult Services (BEAS) and the Bureau of Developmental Services (BDS).
- Umbrella Agency: New Hampshire Department of Health and Human Services (NH DHHS).
- Licensing Authority: NH DHHS Health Facilities Administration (HFA) issues the required operating licenses.
- Waiver Administration (Aging): Bureau of Elderly and Adult Services (BEAS) manages the Choices for Independence (CFI) waiver.
- Waiver Administration (Disabilities): Bureau of Developmental Services (BDS) manages the DD and ABD waivers.
- Medicaid Agency: Office of Medicaid Business and Policy (OMBP) oversees the MMIS and provider enrollment.
- Managed Care Oversight: Medicaid Care Management (MCM) program oversees the three contracted health plans.
3. Gatekeeping Prerequisites: Who Can Even Apply
New Hampshire imposes strict structural preconditions that block applicants from simply enrolling as independent Medicaid providers. There is no Certificate of Need (CON) required for non-medical home care, but network restrictions act as functional gates.
To serve the DD/ABD population, you are structurally blocked unless you secure a subcontract with a regional Area Agency. To serve the CFI population, state Medicaid enrollment is useless without subsequent credentialing and contracting with the MCM health plans.
- DD/ABD Network Restriction: Mandatory subcontracting or affiliation with one of NH's 10 regional Area Agencies (e.g., The Moore Center, Community Crossroads); standalone enrollment is prohibited.
- CFI Network Restriction: Mandatory credentialing and contracting with NH's three MCM health plans (WellSense, NH Healthy Families, AmeriHealth Caritas).
- Licensure Prerequisite: Must obtain a Non-Medical Home Care Provider license (He-P 822) from HFA before a Medicaid enrollment application will be approved.
- Certificate of Need (CON): Not required in New Hampshire for non-medical home care or companion-type services.
- NPI Requirement: Must obtain a Type 2 National Provider Identifier (NPI) prior to initiating the NHMMIS application.
- Physical Location: Must maintain a physical office in NH or a border state that meets HFA administrative requirements.
4. Licensure and Certification Requirements
To provide companion, homemaker, or personal care services in New Hampshire, an agency must be licensed under NH Code of Administrative Rules He-P 822 as a Non-Medical Home Care Service Provider.
This licensure process requires submitting a detailed application to the Health Facilities Administration (HFA), paying the required fees, and passing an initial on-site inspection to verify compliance with administrative and life-safety rules.
- License Category: Non-Medical Home Care Service Provider (He-P 822).
- Application Form: HFA Non-Medical Home Care License Application.
- Initial License Fee: $250 for the initial application (subject to legislative updates).
- Inspection: HFA conducts an initial on-site inspection prior to issuing the license.
- Administrator Qualifications: Must designate an administrator with a high school diploma/GED and at least one year of relevant supervisory experience.
- Renewal Cycle: Licenses must be renewed annually with HFA.
5. Medicaid Provider Enrollment
Once licensed, providers must enroll through the [New Hampshire MMIS Health Enterprise Portal](https://nhmmis.nh.gov/portals/wps/portal/ProviderEnrollment). Providers enroll as a Billing Provider, and the application requires uploading specific verification documents.
Under NH rule He-W 520.06, certain home care agencies are designated as "high risk" upon initial enrollment, which triggers mandatory fingerprint-based background checks for all owners with a 5% or greater interest.
- Enrollment Portal: NH MMIS Health Enterprise Portal.
- Provider Type: Enroll as a Billing Provider (Atypical or Typical depending on exact medical/non-medical billing codes used).
- Required Forms: Provider Participation Agreement and Enrollment/Revalidation Signature Page.
- Risk Category: Home care agencies are often designated as "high risk" under He-W 520.06, requiring fingerprint-based background checks.
- Application Fee: $709 (2024 CMS rate) for institutional/agency providers, unless waived by Medicare/Medicaid prior payment.
- MCO Sequencing: State enrollment must be initiated before MCO credentialing can be finalized, though parallel processing is allowed.
6. Staffing, Training and Background Checks
Staffing requirements are dictated by He-P 822 and DHHS background check rules. Agencies must ensure all direct care staff are thoroughly vetted before they have any contact with clients.
Training must cover specific state-mandated topics, and agencies must maintain ongoing supervision and annual continuing education for all non-medical direct care workers.
- Criminal Background Checks: Mandatory NH State Police criminal history record check for all direct care staff prior to client contact.
- Registry Checks: Must check the NH BEAS State Registry (He-W 702) for substantiated cases of abuse, neglect, or exploitation.
- Initial Training: Minimum orientation covering client rights, infection control, emergency procedures, and the agency's policies.
- Ongoing Training: He-P 822 requires at least 6 hours of annual continuing education for non-medical direct care staff.
- Supervision: Routine supervisory visits by the agency administrator or designated supervisor every 6 months.
- Health Screening: Staff must have a physical exam and TB screening prior to client contact.
7. Documentation, Policies and Records
HFA and NH Medicaid require strict, standardized record-keeping. Providers must maintain comprehensive personnel files and detailed client service records that justify the hours billed.
Service plans must be individualized, non-medical in nature, and updated regularly to reflect any changes in the client's condition or living situation.
- Service Plan: A written non-medical care plan must be developed within 5 days of admission and updated annually or upon change in condition.
- Personnel Files: Must contain background check results, TB test results, training logs, and performance evaluations.
- Client Records: Must retain daily service logs, signed by the worker and client, detailing tasks performed and hours worked.
- Incident Reporting: Mandatory reporting of adverse events to HFA and BEAS/BDS within 24-48 hours.
- Record Retention: NH Medicaid requires all clinical and financial records be retained for a minimum of 6 years.
- Emergency Preparedness: Must maintain a written emergency and disaster plan per He-P 822.13.
8. Billing, Rates and Claims
Billing pathways depend entirely on the waiver program. For the CFI waiver, claims are submitted directly to the member's assigned MCM health plan. For DD/ABD waivers, invoices are submitted to the regional Area Agency.
New Hampshire has implemented Electronic Visit Verification (EVV) for personal care and home health services, which may apply to companion-like services depending on the exact billing code used.
- Billing System (MCO): Claims submitted directly to WellSense, NH Healthy Families, or AmeriHealth Caritas via their respective clearinghouses.
- Billing System (DD/ABD): Invoices submitted to the contracted regional Area Agency, which then bills the state.
- Common Codes: S5135 (Companion care, per 15 minutes) or S5130 (Homemaker service, NOS) depending on the exact MCO/Area Agency contract.
- Rate Setting: CFI rates are negotiated with MCOs but often follow the NH Medicaid fee schedule baseline; DD/ABD rates are negotiated with Area Agencies.
- Electronic Visit Verification (EVV): Mandatory for applicable in-home services under the 21st Century Cures Act; NH uses FirstData/Fiserv as the state aggregator.
- ORP Requirement: Any Ordering, Referring, or Prescribing provider listed on a fee-for-service claim must be enrolled in NH Medicaid.
9. Approval Sequence and Timeline
Becoming a fully approved provider is a sequential process that spans multiple agencies. You cannot bill Medicaid until licensure, state enrollment, and MCO/Area Agency contracting are all complete.
Providers should expect the entire end-to-end process to take between 4 and 8 months, largely depending on HFA inspection scheduling and MCO credentialing timelines.
- Step 1: Business Registration: Register the entity with the NH Secretary of State (1-2 weeks).
- Step 2: HFA Licensure: Submit He-P 822 application and pass initial HFA inspection (60-90 days).
- Step 3: NHMMIS Enrollment: Submit Billing Provider application via Health Enterprise Portal (30-60 days).
- Step 4: Fingerprinting: Complete high-risk fingerprinting if mandated by OMBP (2-4 weeks concurrent).
- Step 5: MCO Credentialing (CFI): Apply to the three MCM health plans via CAQH ProView (90-120 days).
- Step 6: Area Agency Contracting (DD/ABD): Negotiate subcontract with regional Area Agency (timeline varies by region).
10. Common Denials and Survey Findings
Applications are frequently delayed or denied due to missing documentation or failure to understand the structural gates. HFA surveyors also frequently cite new agencies for administrative lapses during initial inspections.
In the billing phase, failure to properly utilize the EVV system or listing an unenrolled referring provider will result in immediate claim denials.
- Licensure Denial: Failure to designate a qualified administrator with the required supervisory experience.
- Enrollment Denial: Missing the required Type 2 NPI or failing to upload the signed Provider Participation Agreement.
- Survey Citation: Incomplete BEAS State Registry checks prior to an employee's first day of client contact.
- Survey Citation: Missing or outdated client service plans (failing to update upon change in condition).
- Claim Denial: Unenrolled Ordering, Referring, or Prescribing (ORP) provider listed on the claim.
- Claim Denial: Failure to comply with EVV requirements for applicable in-home services.
11. Key Contacts and Resources
Providers must interact with multiple state portals and bureaus. The NHMMIS Health Enterprise Portal is the central hub for state enrollment, while HFA handles all licensing inquiries.
For managed care credentialing, providers must contact the provider relations departments of the three MCM health plans directly.
- Licensing: NH DHHS Health Facilities Administration (HFA), (603) 271-9039.
- Medicaid Enrollment: NH MMIS Provider Relations, (866) 291-1674.
- Waiver Management (Aging): Bureau of Elderly and Adult Services (BEAS).
- Waiver Management (Disabilities): Bureau of Developmental Services (BDS).
- MCO Credentialing: NH Healthy Families Provider Services, (866) 769-3085.
- Rules Resource: NH Code of Administrative Rules (He-P 822 for Non-Medical Home Care).
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