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New Hampshire - Day Habilitation Services — Licensing, Medicaid Enrollment and Startup Requirements

Last reviewed: 2026-09-10

New Hampshire funds structured daytime programming through the Developmental Disabilities (DD), Acquired Brain Disorder (ABD), and In Home Supports (IHS) waivers under the service name Community Participation Services (CPS), which requires certification by the Health Facilities Administration (HFA). The state is actively transitioning its system to comply with Conflict Free Case Management and Direct Billing requirements, meaning independent agencies must now enroll directly rather than operating exclusively as subcontractors under the state's regional Area Agencies.

Prospective CPS providers must navigate a multi-step approval sequence that mandates a Bureau of Developmental Services (BDS) screening, direct enrollment as a group billing provider in the NH Medicaid Management Information System (MMIS), and HFA certification before any services can be billed. Applicants must also demonstrate full compliance with the HCBS Settings Rule and establish a formal business presence with the New Hampshire Secretary of State prior to initiating the Medicaid enrollment application.

1. Service Definition and Scope

In New Hampshire, traditional day habilitation is categorized and billed as Community Participation Services (CPS) under the state's 1915(c) waivers. This service is designed to foster community integration, build adaptive skills, and provide structured daytime support outside of the participant's residence.

CPS emphasizes meaningful community involvement and must be delivered in settings that fully comply with the CMS HCBS Final Rule, ensuring participants have access to the broader community to the same degree as individuals not receiving Medicaid HCBS.

2. Regulatory and Oversight Agencies

The New Hampshire Department of Health and Human Services (DHHS) oversees all Medicaid waiver services. Within DHHS, specific bureaus handle different phases of the provider lifecycle, from initial screening to facility certification and claims processing.

Providers must interact with multiple distinct entities, including the state's fiscal agent for Medicaid enrollment and the specific division responsible for health facility inspections.

3. Gatekeeping Prerequisites: Who Can Even Apply

Before a provider can submit a Medicaid enrollment application for CPS, they must pass a mandatory screening process conducted by the Bureau of Developmental Services (BDS). This screening verifies the agency's structural readiness and compliance with state administrative rules.

Additionally, the applicant must be registered as a legal business entity in New Hampshire and obtain a National Provider Identifier (NPI). The state's transition to direct billing requires all new entities to apply as group billing providers rather than individual practitioners.

4. Licensure and Certification Requirements

New Hampshire requires all Community Participation Services (CPS) programs to be formally certified by the Health Facilities Administration (HFA). This certification is a distinct step that occurs after the initial BDS screening and Medicaid enrollment applications are processed.

The HFA certification process involves a review of the physical site (if facility-based) and the agency's operational policies to ensure they meet state health and safety standards as outlined in the He-M administrative rules.

5. Medicaid Provider Enrollment

Providers must enroll directly in the New Hampshire Medicaid Management Information System (MMIS), operated by Conduent. Under the state's updated direct billing model, developmental services providers must enroll as a group billing provider.

The enrollment application requires detailed disclosures of ownership, submission of the BDS screening approval, and attestations regarding background checks. Individual direct support professionals do not enroll separately; they operate under the agency's group billing NPI.

6. Staffing, Training and Background Checks

Agencies providing CPS must adhere to strict background check and training mandates as defined in He-M 504. The state requires continuous monitoring of staff eligibility to ensure participant safety.

Providers must attest during enrollment that they will conduct criminal background checks prior to hire and annually thereafter, as well as monthly checks against federal exclusion databases.

7. Documentation, Policies and Records

CPS providers must maintain comprehensive records that demonstrate compliance with both state administrative rules and the federal HCBS Settings Rule. Documentation must clearly link the services provided to the participant's individualized service plan.

Agencies are required to have written policies covering incident reporting, grievance procedures, and emergency response, which are subject to review during HFA certification and BDS audits.

8. Billing, Rates and Claims

With the implementation of Direct Billing in New Hampshire, CPS providers now submit claims directly to the NH MMIS rather than passing them through the regional Area Agencies. Providers can choose to bill directly in the MMIS portal or utilize an enrolled trading partner.

Rates for CPS are established by DHHS and are published in the state's Medicaid fee schedules. Services must be prior-authorized based on the participant's approved budget and service plan.

9. Approval Sequence and Timeline

The pathway to becoming a fully approved CPS provider in New Hampshire is sequential. An applicant cannot proceed to HFA certification until the BDS screening and Medicaid enrollment phases are complete.

Processing times vary based on application completeness and the scheduling of HFA inspections. Providers should anticipate a multi-month process from initial business registration to the final issuance of the Medicaid ID and certification.

10. Common Denials and Survey Findings

Applications for CPS enrollment are frequently delayed or denied due to incomplete documentation or failure to understand the sequential nature of the state's approval process. Submitting a Medicaid application before passing the BDS screening will result in cancellation.

During HFA certification and subsequent audits, providers often face citations for inadequate documentation of HCBS Settings Rule compliance or lapses in mandatory staff background checks.

11. Key Contacts and Resources

Prospective providers must utilize the official DHHS and Conduent portals to access current applications, fee schedules, and administrative rules. The state provides dedicated email contacts for different phases of the enrollment and certification process.

Maintaining open communication with Provider Relations and the Health Facilities Administration is critical for resolving application holds and scheduling required inspections.

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