New Hampshire - Environmental Accessibility Service — Licensing, Medicaid Enrollment and Startup Requirements
Last reviewed: 2026-08-16
In New Hampshire, Environmental Accessibility Services (EAS) provide physical adaptations to a home or vehicle—such as ramps, widened doorways, and roll-in showers—that are necessary to ensure the health, welfare, and safety of a Medicaid waiver participant. These services are authorized under the state's 1915(c) Home and Community-Based Services (HCBS) waivers, primarily the Choices for Independence (CFI) Waiver, the Developmental Disabilities (DD) Waiver, and the Acquired Brain Disorder (ABD) Waiver, governed by N.H. Admin. Code § He-E 801.17.
The single biggest structural barrier to entry for an EAS provider in New Hampshire is that this is not a direct-to-consumer service that can be billed independently upon Medicaid enrollment. Access to clients and reimbursement is strictly gated by two mechanisms: for the CFI waiver, every project requires a prior authorization initiated by a participant's Case Manager using Form 3715; for the DD and ABD waivers, providers are functionally blocked from participating unless they secure a vendor contract or affiliation agreement with one of New Hampshire's 10 designated regional Area Agencies, which control the local provider networks.
1. Service Definition and Scope
Under N.H. Admin. Code § He-E 801.17, Environmental Accessibility Services (EAS) are defined as physical adaptations to a participant's private residence or primary vehicle. These modifications must be tied to an assessed medical or functional need and documented in the participant's person-centered service plan to enable greater independence or prevent institutionalization.
The scope of EAS is strictly limited to accessibility and safety. New Hampshire explicitly excludes adaptations that add square footage to the home, general maintenance, or upgrades that are not medically necessary. All structural work must comply with the New Hampshire State Building Code.
- Covered Adaptations: Installation of wheelchair ramps, stair lifts, widened doorways, grab bars, and roll-in showers.
- Vehicle Modifications: Lifts and adaptive controls for the primary vehicle used to transport the waiver participant.
- Excluded Services: General home maintenance, roof repair, central air conditioning, and any modifications that add total square footage to the residence.
- Code Compliance: All modifications must meet the requirements of the New Hampshire State Building Code under RSA 155-A:2.
- Infrastructure Limits: Electrical or plumbing work is only covered if it is strictly required to support the authorized adaptation (He-E 801.17(c)(4)).
- Facility Exclusions: Adaptations to residential care facilities or other licensed facilities are generally excluded, except for specific approved adult family care homes.
2. Regulatory and Oversight Agencies
The New Hampshire Department of Health and Human Services (NH DHHS) is the single state Medicaid agency. Within DHHS, the Division of Long Term Supports and Services (DLTSS) oversees all HCBS waiver programs and sets the policy for Environmental Accessibility Services.
Because EAS involves construction and trade work, providers must also interact with state licensing boards for their subcontractors. While DHHS manages the Medicaid funding, the actual trade credentials required to perform the work are overseen by the state's professional licensing bodies.
- NH DHHS Division of Long Term Supports and Services (DLTSS): The primary state authority overseeing all HCBS waivers and approving EAS policies.
- Bureau of Elderly and Adult Services (BEAS): The division within DLTSS that administers the Choices for Independence (CFI) waiver.
- Bureau of Developmental Services (BDS): The division within DLTSS that administers the Developmental Disabilities (DD) and Acquired Brain Disorder (ABD) waivers.
- Regional Area Agencies: 10 designated non-profit organizations that manage DD/ABD waiver service coordination, provider contracting, and local network adequacy.
- NH Office of Professional Licensure and Certification (OPLC): The state agency that issues and verifies mandatory trade licenses (e.g., plumbing, electrical) for contractors and subcontractors.
- Centers for Medicare & Medicaid Services (CMS): The federal agency that approves New Hampshire's 1915(c) waiver applications and sets overarching HCBS settings rules.
3. Gatekeeping Prerequisites: Who Can Even Apply
New Hampshire does not require a Certificate of Need (CoN) for Environmental Accessibility Services, nor is there a closed enrollment window for the state Medicaid program. However, the state utilizes a highly decentralized, gatekept system for its HCBS waivers that blocks standalone providers from simply enrolling and finding their own clients.
To operate under the DD or ABD waivers, a provider must be accepted into the network of a regional Area Agency. For the CFI waiver, a provider cannot initiate any service without a Case Manager submitting a specific prior authorization request. Without these structural affiliations and approvals, a Medicaid provider ID generates no revenue.
- Area Agency Affiliation (DD/ABD Waivers): Providers must establish a vendor agreement or contract with one of the 10 regional Area Agencies; direct independent billing without this network affiliation is functionally blocked.
- Case Manager Prior Authorization (CFI Waiver): Services cannot be initiated, and applications for specific projects will not be accepted, without a completed Form 3715 submitted by the participant's designated case manager.
- Business Registration: Applicants must be registered and in good standing with the New Hampshire Secretary of State before applying for Medicaid enrollment.
- Trade Licensure Prerequisite: While NH lacks a statewide general contractor license, any provider performing plumbing or electrical work must hold active OPLC licensure before bidding on projects.
- NPI Requirement: Providers must obtain a National Provider Identifier (Type 2 for organizations) prior to initiating the NH MMIS enrollment process.
4. Licensure and Certification Requirements
New Hampshire DHHS does not issue a distinct "Environmental Accessibility Services License" or "HCBS Provider License" for home modification contractors. Instead, providers are certified through the Medicaid enrollment process by proving they hold the standard business and trade credentials required to perform structural work safely in the state.
Providers must ensure that all work meets state and local building codes. If the primary EAS provider subcontracts specialized work, they bear the regulatory burden of proving those subcontractors hold the correct New Hampshire trade licenses.
- General Contracting: New Hampshire does not issue a statewide general contractor license, but providers must comply with all local municipal permitting and inspection requirements.
- Trade Licenses: Any electrical or plumbing work must be performed by individuals holding active, valid licenses from the NH Office of Professional Licensure and Certification (OPLC).
- Building Code Affirmation: Providers must sign a written agreement affirming that all work will meet the requirements of the NH State Building Code (RSA 155-A:2).
- Subcontractor Verification: The enrolled EAS provider must document and affirm that any subcontractors involved in the work are appropriately licensed by the state.
- Insurance Requirements: Providers must maintain active general liability and workers' compensation insurance as required by standard state business laws.
- Capacity Statement: Providers must supply a written statement that the proposed adaptation can be completed within the current electrical or plumbing capacity of the home (He-E 801.17(c)(5)).
5. Medicaid Provider Enrollment
All EAS providers must enroll in the New Hampshire Medicaid program through the state's designated portal. Enrollment allows the provider to be assigned a NH Medicaid ID, which is required to receive prior authorizations and submit claims.
Providers enroll as HCBS Waiver Providers and must select the specific specialties related to environmental modifications. The process requires submitting business documentation and passing state screening criteria.
- Enrollment System: Applications must be submitted electronically through the NH MMIS Health Enterprise Portal (www.nhmmis.nh.gov).
- Provider Type: Applicants must select "Enrollment" and register as a Group Provider or Atypical Provider under the HCBS Waiver category, depending on their exact corporate structure.
- Application Fee: Providers are subject to the federal ACA institutional provider application fee (approximately $731 for 2024) unless they are already enrolled in Medicare or another state's Medicaid program.
- Required Documents: Submission must include an IRS EIN confirmation letter, a completed W-9, and a Certificate of Good Standing from the NH Secretary of State.
- Revalidation: Enrolled providers must complete the revalidation process through the NH MMIS portal every 5 years to maintain active billing status.
6. Staffing, Training and Background Checks
Because EAS providers are construction contractors rather than direct-care clinicians, they are not subject to the extensive clinical training requirements of nursing or personal care staff. However, because they operate in the homes of vulnerable adults, strict background check requirements apply.
Providers must also ensure that they provide basic training to the participant and their caregivers on how to safely use the newly installed adaptations, such as a ceiling lift or ramp.
- Criminal Background Checks: Required for all owners, employees, and subcontractors who will be entering the waiver participant's home, processed via the NH State Police.
- State Registry Checks: Providers must verify staff against the NH DHHS BEAS and BDS state registries to ensure no founded complaints of abuse, neglect, or exploitation exist.
- Federal Exclusion Checks: Providers must check the federal HHS-OIG List of Excluded Individuals/Entities (LEIE) monthly to ensure no staff or subcontractors are excluded from Medicaid.
- Participant Training Plan: Per He-E 801.17(d)(2)c, the provider must supply a proposed training plan for the participant and caregiver to ensure safe use of the adaptation.
- Subcontractor Vetting: The primary enrolled provider is responsible for maintaining background check records for all subcontracted laborers on the job site.
7. Documentation, Policies and Records
EAS providers must maintain comprehensive project files that align perfectly with the case manager's prior authorization. State auditors and Area Agencies will review these files to ensure funds were spent exactly as authorized.
Records must prove that the work was medically necessary, completed to code, and that the participant was trained on its use. All Medicaid records in New Hampshire must be retained for a minimum of six years.
- Evaluation Copy: Providers must retain a copy of the NH Medicaid-enrolled licensed practitioner's evaluation describing the medical or functional need and required measurements.
- Prior Authorization Form: Providers must keep the fully executed Form 3715 (Choices for Independence Prior Authorization Request Form) for CFI waiver projects.
- Permits and Inspections: Files must include copies of all local municipal building permits pulled for the project and the final municipal inspection sign-offs.
- Capacity Statement Record: A retained written statement from the provider confirming the home's electrical/plumbing capacity can handle the modification.
- Bid and Proposal Records: Copies of the original itemized proposals submitted to the Case Manager or Area Agency, including material and labor breakdowns.
- Record Retention: All project, billing, and subcontractor licensing records must be securely retained for at least 6 years per NH DHHS Medicaid rules.
8. Billing, Rates and Claims
Environmental Accessibility Services are reimbursed on a milestone or project-completion basis rather than an hourly rate. Providers submit bids for specific projects, and if approved, that bid becomes the authorized reimbursement rate.
Claims are submitted electronically through the state's MMIS system. Providers must ensure that the prior authorization number is attached to every claim to avoid automatic denials.
- Billing Portal: All claims are submitted electronically through the NH MMIS Health Enterprise Portal.
- Prior Authorization (PA) Requirement: Every claim must include the specific PA number generated by DHHS/DLTSS; claims without a matching PA will be denied.
- Procedure Codes: Services are typically billed using standard HCBS codes such as S5165 (Home modifications; per service), often with waiver-specific modifiers.
- Rate Structure: Reimbursement is paid based on the approved, itemized bid/proposal amount authorized by the state prior to the start of work.
- Waiver Caps: Reimbursement is strictly subject to the lifetime or annual financial limits defined in the specific waiver (e.g., CFI or DD waiver EAS caps).
- Third-Party Liability: Providers must ensure the modification is not duplicative of what a landlord is legally required to provide under the ADA or Fair Housing Act.
9. Approval Sequence and Timeline
Becoming an active EAS provider involves a two-tiered sequence: first, enrolling as a Medicaid provider at the state level, and second, securing project-specific authorizations through local Case Managers or Area Agencies.
The initial Medicaid enrollment can take one to two months, but securing the first paid project depends entirely on local network needs and the speed of the prior authorization process.
- Step 1: Register the business with the NH Secretary of State and obtain an NPI and EIN (1-2 weeks).
- Step 2: Submit the Medicaid enrollment application via the NH MMIS Health Enterprise Portal (30-60 days for DHHS review and approval).
- Step 3: Establish vendor agreements or contracts with regional Area Agencies (for DD/ABD waivers) (timeline varies by agency).
- Step 4: Receive a request for a bid/proposal from a waiver Case Manager for a specific participant's home modification.
- Step 5: Submit the itemized proposal and wait for the Case Manager to submit Form 3715 and receive DHHS Prior Authorization (14-30 days).
- Step 6: Complete the work, obtain municipal inspection sign-offs, and submit the claim via NH MMIS.
10. Common Denials and Survey Findings
Provider enrollment and project claims are frequently delayed or denied due to incomplete documentation or failure to follow the strict prior authorization sequence. DHHS and Area Agencies actively audit EAS projects for compliance.
The most common financial penalty occurs when a provider begins work before the official prior authorization is issued, resulting in the state refusing to pay for the completed modifications.
- Unlicensed Subcontractors: Denials or audit findings occur if the provider fails to maintain proof that plumbers or electricians held active OPLC licenses during the project.
- Missing Prior Authorization: Performing any structural work before the official DHHS prior authorization (via Form 3715) is fully approved results in absolute non-payment.
- Scope Creep: Billing for general home renovations (e.g., fixing a leaky roof) rather than the specific, authorized accessibility adaptation.
- Incomplete Form 3715: Delays in project approval because the Case Manager failed to include the required medical/functional evaluation or the participant training plan.
- Background Check Failures: Audit findings for allowing unvetted construction crew members or subcontractors into a vulnerable waiver participant's home.
- Code Violations: Failing to pull local municipal permits or failing to obtain final inspection sign-offs, violating the RSA 155-A:2 affirmation.
11. Key Contacts and Resources
EAS providers must navigate multiple state systems, from the Medicaid billing portal to the professional licensing boards. Maintaining contact with the correct division is essential for resolving enrollment or authorization issues.
For DD and ABD waiver providers, the most important contacts are the local Area Agencies, which can be located through the Community Support Network, Inc. (CSNI).
- NH MMIS Provider Enrollment: (603) 223-4774 or (866) 291-1674; portal at nhmmis.nh.gov for all Medicaid enrollment and billing inquiries.
- NH DHHS Bureau of Elderly and Adult Services (BEAS): Oversees CFI waiver policy and Form 3715 prior authorizations.
- NH DHHS Bureau of Developmental Services (BDS): (603) 271-5034; oversees DD and ABD waiver policies.
- NH Office of Professional Licensure and Certification (OPLC): The state agency used to verify active trade licenses for electricians and plumbers.
- Community Support Network, Inc. (CSNI): The association representing New Hampshire's 10 regional Area Agencies, essential for DD/ABD networking.
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