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North Dakota - Adult Companion Services — Licensing, Medicaid Enrollment and Startup Requirements

Last reviewed: 2026-08-16

In North Dakota, Companionship Services are delivered under the state's Medicaid Waiver for Home and Community Based Services (HCBS). This service provides non-medical care, supervision, and socialization to eligible aged and disabled adults who are experiencing the negative effects of social isolation, allowing them to remain safely in their own homes and communities.

The single biggest structural barrier to entry for this service in North Dakota is the dual-approval requirement: an applicant cannot simply enroll in Medicaid. Before a provider can even access the Medicaid enrollment portal, they must first apply for and be granted status as a Qualified Service Provider (QSP) through the North Dakota Department of Health and Human Services (ND HHS) Aging Services Division. Without an approved QSP authorization letter, any Medicaid application will be immediately rejected.

1. Service Definition and Scope

Under North Dakota HHS Policy Manual 525-05-30-23, Companionship Services are defined as non-medical care, supervision, and socialization provided to an eligible recipient. The service is specifically targeted at individuals experiencing social isolation and is designed to help them work toward a therapeutic or community-integration goal.

This service is strictly non-medical. While a companion may assist with incidental instrumental activities of daily living (IADLs) during their visit, they are prohibited from providing hands-on personal care, medication administration, or medical treatments.

2. Regulatory and Oversight Agencies

The North Dakota Department of Health and Human Services (ND HHS) is the primary umbrella agency governing this service. Within ND HHS, responsibilities are divided between the Aging Services Division and the Medical Services Division.

Unlike standard medical providers whose enrollment is processed by the state's fiscal agent (Noridian), Qualified Service Providers (QSPs) are managed directly by ND HHS. The Aging Services Division handles the HCBS waiver rules and QSP certification, while the Medical Services Division oversees the final Medicaid MMIS enrollment.

3. Gatekeeping Prerequisites: Who Can Even Apply

North Dakota does not require a Certificate of Need (CON) or a competitive Request for Proposals (RFP) procurement process to provide Companionship Services. The state operates an open-network model for HCBS waivers, meaning any willing provider who meets the standards can apply.

However, the absolute structural precondition blocking any applicant is the Qualified Service Provider (QSP) designation. A provider cannot submit a Medicaid enrollment application on the ND Health Enterprise MMIS portal without first securing an approved QSP status from the ND HHS Aging Services Division. There are no mandatory network affiliations or managed care subcontracts required for this specific FFS waiver service.

4. Licensure and Certification Requirements

North Dakota does not issue a distinct facility or agency license for Companionship Services. Instead, providers must meet the certification standards to become an Agency Qualified Service Provider (QSP) under North Dakota Administrative Code (NDAC) 75-03-23.

To achieve this, an agency must submit a comprehensive QSP application packet demonstrating administrative capacity, appropriate liability coverage, and compliance with federal HCBS settings rules. Agencies must also designate an agency manager who is responsible for ensuring all direct care staff meet state competency standards.

5. Medicaid Provider Enrollment

Once QSP status is officially granted by the Aging Services Division, the agency must enroll as a North Dakota Medicaid provider. This mandatory step is completed electronically through the ND Health Enterprise MMIS portal.

During this phase, the agency must upload their QSP approval letter, complete ownership disclosures, and pay the federal Medicaid application fee. Because Companionship Services are non-medical, agencies typically enroll as Atypical Providers unless they hold an NPI for other medical services.

6. Staffing, Training and Background Checks

Direct care workers providing Companionship Services must meet ND HHS competency standards before delivering care. Agencies are strictly responsible for verifying that their employees pass required background checks and complete the ND HHS-approved QSP orientation.

Because companions work with vulnerable adults, North Dakota requires comprehensive background screening. Staff must also demonstrate competency in communication, emergency procedures, and recognizing abuse, neglect, and exploitation.

7. Documentation, Policies and Records

QSP agencies must maintain strict documentation to support Medicaid claims and demonstrate compliance with HCBS waiver rules. Services cannot be initiated or billed without a formal prior authorization from the county HCBS case manager.

Agencies must maintain individualized care plans that align with the state's authorization. Daily service logs must be kept meticulously, as North Dakota frequently audits QSP records to recover funds for undocumented services.

8. Billing, Rates and Claims

Companionship Services are reimbursed on a fee-for-service basis through the ND Health Enterprise MMIS. Providers must bill using the specific HCPCS codes authorized on the client's service plan.

Claims must exactly match the authorized units and dates of service. Billing for units in excess of the county case manager's authorization will result in automatic claim denials.

9. Approval Sequence and Timeline

The end-to-end process for becoming a billable Companionship Services QSP in North Dakota typically takes 60 to 90 days. This timeline is heavily dependent on the provider submitting a complete, error-free application.

Delays are most commonly caused by incomplete QSP applications, missing proof of liability insurance, or delayed background check results from the BCI.

10. Common Denials and Survey Findings

ND HHS conducts periodic reviews of QSP agencies to ensure compliance with waiver standards. Deficiencies often stem from administrative oversights rather than clinical errors.

Common audit findings include billing for services without a valid, current authorization from the case manager, or failing to maintain daily logs with exact start and stop times.

11. Key Contacts and Resources

Prospective providers should utilize the official ND HHS portals and contact the Aging Services Division for QSP-specific guidance. Because QSP enrollment bypasses the standard Noridian contractor, all QSP inquiries must go directly to the state.

The ND Health Enterprise MMIS portal is the central hub for the final step of Medicaid enrollment and subsequent claims submission.

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