New York - Transitional Assistance Services — Licensing, Medicaid Enrollment and Startup Requirements

Last reviewed: 2026-08-16

In New York, Transitional Assistance Services are officially administered as Community Transition Services (CTS) or Moving Assistance under the state's 1915(c) Nursing Home Transition and Diversion (NHTD) and Traumatic Brain Injury (TBI) Medicaid waivers. These services provide critical, one-time funding to cover the essential setup expenses—such as security deposits, basic furniture, and utility activation fees—required to help a Medicaid member move from an institutional setting into a community-based home.

The single biggest structural barrier to entry for this service in New York is the mandatory Regional Resource Development Center (RRDC) gatekeeping process. A prospective provider cannot simply submit a Medicaid enrollment application to the state; they must first apply to, be interviewed by, and receive a formal letter of recommendation and rate transmittal from their local RRDC before the Department of Health will even allow eMedNY to process their provider enrollment.

1. Service Definition and Scope

Under New York's NHTD and TBI waivers, Community Transition Services (CTS) and Moving Assistance are defined as non-recurring set-up expenses for individuals transitioning from a nursing facility to a living arrangement in a private residence where the person is directly responsible for their own living expenses. The service is designed to remove financial barriers to community integration.

The scope of the service is strictly limited to essential household setup and is capped at a specific lifetime or per-transition dollar amount. It cannot be used to subsidize ongoing living expenses or purchase luxury items.

• Covered Expense: Security deposits and first month's rent required to obtain a lease on an apartment or home.
• Covered Expense: Essential household furnishings, including a bed, dining table, chairs, and basic kitchenware.
• Covered Expense: Set-up fees or deposits for essential utility access, including telephone, electricity, and heating.
• Covered Expense: Health and safety assurances, such as one-time pest eradication or deep cleaning prior to occupancy.
• Excluded Expense: Ongoing monthly rental or mortgage payments, food groceries, and regular monthly utility charges.
• Service Cap: Expenditures are typically capped at $5,000 per enrollee per transition, and every item must be pre-approved in the Service Plan.

2. Regulatory and Oversight Agencies

The administration of waiver services in New York is a bifurcated system involving both state-level oversight and regional administration. The New York State Department of Health (DOH) holds the ultimate authority over the Medicaid state plan and the 1915(c) waivers.

However, DOH contracts with regional entities to manage the day-to-day operations, provider network adequacy, and participant enrollment. Providers must satisfy the requirements of both the regional contractors and the state fiscal agents.

• State Agency: The NYS Department of Health (DOH) Office of Aging and Long Term Care (OALTC) manages the overarching waiver authorities.
• Regional Authority: Regional Resource Development Centers (RRDCs) manage local provider networks, review provider applications, and conduct mandatory interviews.
• Fiscal Agent: eMedNY (operated by GDIT) processes Medicaid enrollment applications, assigns MMIS IDs, and handles claims processing.
• Compliance Oversight: The NYS Office of the Medicaid Inspector General (OMIG) audits provider billing, documentation, and mandatory compliance programs.

3. Gatekeeping Prerequisites: Who Can Even Apply

New York strictly controls access to the NHTD and TBI waiver provider networks through a regional gatekeeping model. You cannot directly apply to eMedNY for CTS or Moving Assistance rate codes without prior regional approval.

The state requires providers to demonstrate existing community ties and organizational capacity before they are permitted to bill Medicaid for transition services. If a provider bypasses the regional network manager, their state application will be immediately rejected.

• Regional Sponsorship: Applicants must obtain an application packet from, submit it to, and be interviewed by the local RRDC for their specific region.
• RRDC Recommendation: DOH will not process an eMedNY application without a formal approval letter and a rate transmittal document generated by the RRDC.
• Business Establishment: The agency must be an established legal entity in New York with an active EIN and registered with the NY Department of State.
• Provider Compliance Certification: Applicants must certify an active compliance program under NYS Social Services Law Section 363-d prior to enrollment.
• Network Need: RRDCs may restrict new provider approvals based on regional network adequacy and the current volume of transitioning participants.

4. Licensure and Certification Requirements

New York does not issue a distinct "Transitional Assistance License" or "Moving Assistance License." Because this service involves purchasing goods and coordinating logistics rather than providing direct clinical care, it does not require an Article 28 or Article 36 facility license.

Instead, providers are approved through a certification process tied directly to the waiver. Providers are typically established non-profit community organizations, housing authorities, or existing Licensed Home Care Services Agencies (LHCSAs) that add CTS to their approved waiver services.

• Corporate Authority: Must provide Articles of Incorporation or a Certificate of Authority to conduct business in New York State.
• Base Licensure: While not strictly required for CTS alone, many providers hold a Licensed Home Care Services Agency (LHCSA) license under NYCRR Title 10 Article 36 to provide companion services.
• Insurance Mandate: Must maintain general liability and professional liability insurance meeting DOH minimums, with proof submitted to the RRDC.
• Waiver Certification: Must sign the specific NHTD or TBI Provider Agreement acknowledging adherence to waiver-specific regulations and DOH manuals.
• Vehicle Insurance: If the agency's own staff and vehicles are transporting goods or individuals, commercial auto liability insurance is required.

5. Medicaid Provider Enrollment

Once the RRDC approves the agency and issues the rate transmittal, the provider must formally enroll in the New York Medicaid program through eMedNY. This process links the agency's tax ID to the specific waiver rate codes.

Enrollment requires submitting a physical application packet to the eMedNY PO Box in Rensselaer, NY. Electronic submission is not fully available for all initial waiver provider enrollments.

• System: eMedNY is New York's Medicaid Management Information System used for enrollment and billing.
• Form EMEDNY-490602: The Electronic Transmitter Identification Number (ETIN) Certification Statement is required for all new enrollments and must have an original signature.
• Form SS-4: An IRS Assignment Letter verifying the Federal Employer Identification Number (FEIN) is required; a W-9 alone is not acceptable.
• Application Fee: Subject to the ACA institutional provider application fee (approximately $709 for 2024) unless waived or already paid to Medicare.
• Revalidation: Providers must revalidate their Medicaid enrollment every 5 years under 42 CFR 455.414.

6. Staffing, Training and Background Checks

Staff coordinating Moving Assistance must meet DOH qualifications for waiver services, ensuring they understand housing logistics, Medicaid rules, and the needs of individuals leaving institutional care.

New York mandates strict background checks for any staff member who will have direct contact with waiver participants or access to their funds and property.

• Staff Qualifications: Coordinators typically must possess a Bachelor's degree in health or human services, or equivalent verifiable experience in housing or case management.
• Criminal History Record Check (CHRC): Mandatory fingerprinting through the DOH CHRC system for all staff with direct patient contact.
• Exclusion Screening: Agencies must conduct monthly checks of all staff against the NYS OMIG Exclusion List and the federal OIG LEIE.
• State Central Register (SCR): Clearance through the NYS Office of Children and Family Services (OCFS) is required if the provider serves minors.
• Mandatory Training: Staff must complete RRDC-sponsored basic orientation and waiver-specific training before providing or billing for services.

7. Documentation, Policies and Records

Because CTS involves the expenditure of Medicaid funds on physical goods and deposits, providers must maintain exhaustive financial documentation. OMIG heavily scrutinizes these one-time expenses during audits.

Providers must prove that every dollar billed was spent directly on the participant's transition and that the participant actually received the goods.

• Service Plan: All transition expenses must be explicitly detailed, itemized, and pre-authorized in the participant's Initial Service Plan (ISP).
• Receipts and Invoices: Original store receipts and vendor invoices for all purchased goods (furniture, deposits) must be retained in the participant's file.
• Inventory Log: A signed inventory log confirming the delivery of all purchased items to the participant's community home must be kept on file.
• Policy Manual: Agencies must maintain written policies on client intake, financial management, and incident reporting.
• Record Retention: New York State requires all Medicaid records, including receipts and logs, to be securely retained for a minimum of six years from the date of payment.

8. Billing, Rates and Claims

Community Transition Services are billed as a one-time or milestone-based expense rather than an hourly rate. Claims are submitted via eMedNY using specific rate codes assigned by DOH during the enrollment process.

Providers act as pass-through entities for these funds; they purchase the approved items or pay the deposits, and then bill Medicaid for reimbursement up to the authorized cap.

• Billing System: Claims are submitted electronically to eMedNY using the 837I or 837P format, or manually via the ePACES web portal.
• Rate Codes: DOH assigns specific 4-digit rate codes for NHTD/TBI Moving Assistance upon RRDC approval.
• Reimbursement Structure: Billed at actual cost up to the authorized cap (e.g., $5,000), not to exceed the exact amount approved in the Service Plan.
• Prior Authorization: The RRDC must authorize the specific dollar amount in the eMedNY system before the provider's claim will clear.
• Timely Filing: Claims must generally be submitted within 90 days of the date of service, which is defined as the date the expense was incurred or the transition occurred.

9. Approval Sequence and Timeline

The end-to-end approval process in New York is lengthy due to the dual regional and state review requirements. Providers cannot expedite the state enrollment until the regional gatekeeper has completed their process.

Prospective providers should expect a minimum of 3 to 6 months from their initial contact with the RRDC to achieving active eMedNY billing status.

• Step 1: Submit Letter of Intent and full application packet to the regional RRDC (1-2 months for review and interview scheduling).
• Step 2: Complete the RRDC Interview and receive conditional regional approval (2-4 weeks).
• Step 3: RRDC submits the formal recommendation and rate transmittal directly to DOH (1-2 weeks).
• Step 4: Provider submits the eMedNY enrollment application to GDIT/eMedNY in Rensselaer (30-60 days for processing).
• Step 5: DOH uploads the approved rate codes into eMedNY, activating the provider's MMIS ID for billing.

10. Common Denials and Survey Findings

Applications and claims are frequently delayed or denied due to administrative errors or failure to follow the strict RRDC protocols. State audits frequently target transition services due to the high risk of financial mismanagement.

Providers must ensure absolute alignment between the RRDC-approved Service Plan, the store receipts, and the final Medicaid claim.

• Application Denial: Submitting an eMedNY application without the required RRDC approval letter and rate transmittal will result in immediate rejection.
• Application Return: Missing the original, wet-ink signature on the EMEDNY-490602 ETIN Certification Statement.
• Claim Denial: Billing for transition expenses that were not explicitly pre-authorized and itemized in the RRDC-approved Service Plan.
• Audit Finding: Failure to maintain original store receipts or signed delivery logs for purchased furniture and household goods.
• Audit Finding: Billing Medicaid for prohibited items such as monthly rent, food, or entertainment electronics.

11. Key Contacts and Resources

Providers must coordinate closely with both state and regional entities to maintain compliance and resolve billing issues. The primary portals for information are the DOH waiver pages and the eMedNY provider site.

Establishing a strong relationship with the regional RRDC is the most critical component of successfully operating as a waiver provider in New York.

• eMedNY Call Center: 1-800-343-9000 for Medicaid enrollment status and ePACES billing assistance.
• NYS DOH Waiver Management: The DOH Office of Aging and Long Term Care (OALTC) oversees the NHTD and TBI waivers at the state level.
• Regional Resource Development Centers (RRDCs): The mandatory local contact for waiver provider applications; contact information varies by NY region.
• eMedNY Provider Portal: www.emedny.org for enrollment forms, provider manuals, and access to the ePACES billing system.
• NYS OMIG: The Office of the Medicaid Inspector General provides compliance program guidelines and maintains the state exclusion list.

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