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

Last reviewed: 2026-09-10

The North Dakota Department of Health and Human Services (HHS) funds Companionship services through the 1915(c) Medicaid Waiver for Home and Community Based Services (Waiver ND.0273). The state does not issue a distinct facility license for this service; instead, individuals and agencies must be approved as Qualified Service Providers (QSPs) under North Dakota Administrative Code 75-03-23.

Applicants must secure designation as a QSP through the HHS Medical Services Division before delivering non-medical supervision and socialization. Approval requires passing fingerprint-based background checks and submitting proof of competency, such as an active North Dakota Certified Nursing Assistant (CNA) license or completion of state-approved training modules, directly to the QSP enrollment unit rather than through the state's general Noridian enrollment contractor.

1. Service Definition and Scope

In North Dakota, Companionship (historically referred to as Adult Companion Services) provides non-medical care, supervision, and socialization to functionally impaired adults. The service is designed to ensure the health and safety of participants who cannot be left alone safely.

Providers assist with instrumental activities of daily living (IADLs) that are incidental to the companionship, but they are strictly prohibited from providing hands-on nursing care or medical administration.

• Service Name: Companionship
• Target Population: Aged and disabled adults enrolled in the North Dakota 1915(c) HCBS Waiver
• Covered Activities: Non-medical supervision, socialization, and incidental assistance with light housekeeping or meal preparation
• Excluded Activities: Hands-on medical care, medication administration, and personal care tasks requiring nursing delegation
• Setting: Delivered in the participant's private home or community settings, excluding licensed adult foster care or basic care facilities

2. Regulatory and Oversight Agencies

The North Dakota Department of Health and Human Services (HHS) serves as the umbrella agency overseeing HCBS waivers and Medicaid enrollment. Within HHS, specific divisions handle waiver administration and provider credentialing.

The Aging Services Division manages the HCBS waiver policies, while the Medical Services Division processes the Qualified Service Provider (QSP) enrollments.

• Operating Agency: North Dakota HHS Aging Services Division (https://www.hhs.nd.gov/aging)
• Medicaid Authority: North Dakota HHS Medical Services Division (https://www.hhs.nd.gov/healthcare/medicaid)
• Enrollment Portal: ND Health Enterprise MMIS (https://www.hhs.nd.gov/healthcare/medicaid/provider)
• Background Check Unit: North Dakota Bureau of Criminal Investigation (https://attorneygeneral.nd.gov/law-enforcement/bureau-of-criminal-investigation)

3. Gatekeeping Prerequisites: Who Can Even Apply

North Dakota operates an open-enrollment, fee-for-service model for HCBS Companionship providers. There are no closed managed care networks, procurement windows, or Certificate of Need (CON) requirements blocking new applicants.

Any willing provider who meets the state's Qualified Service Provider (QSP) competency and background check standards may submit an application at any time.

• Certificate of Need: None exists for HCBS QSP companionship services in North Dakota
• Network Status: Open enrollment; North Dakota does not use closed managed care organization (MCO) networks for this waiver
• Moratoria: No current state or federal moratoria block new QSP companionship applications
• Contracting Requirement: Must sign a North Dakota Medicaid Provider Agreement directly with the state; no third-party lead agency affiliation is required
• Procurement: No Request for Proposals (RFP) or competitive bidding is required to become a provider

4. Licensure and Certification Requirements

North Dakota does not issue a traditional facility license for companionship agencies. Providers must instead obtain certification as a Qualified Service Provider (QSP) under state administrative rules.

Agencies must enroll as a QSP Agency Provider and ensure all direct care employees meet the state's individual competency standards before providing billable services.

• Regulatory Citation: North Dakota Administrative Code (NDAC) 75-03-23 (Provision of Home and Community-Based Services)
• Agency QSP Status: Agencies must obtain a QSP Agency Provider designation and maintain rosters of qualified staff
• Individual QSP Status: Solo practitioners can enroll directly as Individual QSPs without forming an agency
• Competency Standard: Direct care staff must hold a current ND CNA, RN, or LPN license, or complete the ND HHS-approved QSP training videos and pass the competency evaluation
• Age Requirement: All direct service providers must be at least 18 years of age

5. Medicaid Provider Enrollment

QSPs enroll directly with ND HHS, bypassing the state's general Medicaid contractor, Noridian Healthcare Solutions. Applications are processed exclusively through the ND Health Enterprise MMIS portal.

Providers must complete a four-step enrollment process, which includes verifying they are not already enrolled, submitting the online application, and completing all QSP-specific attestations.

• General Contractor Exception: QSPs do not enroll through Noridian Healthcare Solutions; they use the dedicated QSP enrollment track within HHS
• System: ND Health Enterprise MMIS portal
• NPI Requirement: Must obtain a National Provider Identifier (NPI) and register with the appropriate taxonomy code for in-home supportive care
• Application Fee: The federal Medicaid application fee applies to agency providers unless waived by prior Medicare enrollment
• Revalidation: Providers are required to revalidate their Medicaid enrollments at least once every five years

6. Staffing, Training and Background Checks

Direct support professionals must pass strict background checks and prove competency before delivering companionship services. Agencies are responsible for maintaining these records for state review.

Background checks are processed through the North Dakota Bureau of Criminal Investigation (BCI) and include both state and federal fingerprint-based reviews.

• Criminal History: Fingerprint-based background checks through the ND BCI and FBI are mandatory for all direct care staff
• Registry Checks: Staff must clear the North Dakota Child Abuse and Neglect Registry and the federal Medicaid Exclusion List
• First Aid and CPR: Staff must maintain current CPR and First Aid certifications
• Training Documentation: Agencies must maintain a roster of staff who have completed the QSP competency evaluation or hold active ND nursing/CNA licenses
• Supervision: Agency providers must designate a qualified supervisor to oversee direct care staff

7. Documentation, Policies and Records

QSPs must adhere to strict documentation standards outlined in the North Dakota QSP Agency Provider Handbook. Services must align exactly with the authorizations issued by regional HCBS Case Managers.

North Dakota mandates the use of Electronic Visit Verification (EVV) for in-home services to comply with the federal 21st Century Cures Act.

• Care Plan: Services must strictly follow the HCBS Case Manager's authorized care plan and service limits
• Service Records: Documentation must include the date, start and end times, specific activities provided, and participant verification
• EVV Mandate: Electronic Visit Verification is required for companionship services delivered in the home
• Record Retention: All service, training, and billing records must be retained for a minimum of five years
• Incident Reporting: Providers must have written policies for reporting critical incidents to the regional human service center

8. Billing, Rates and Claims

Companionship services are billed in 15-minute increments using standard HCPCS codes via the ND Health Enterprise MMIS portal. Rates are established by the North Dakota legislature and published by the Medical Services Division.

Providers cannot bill for services until a formal prior authorization is generated by the participant's HCBS Case Manager.

• Billing System: Claims are submitted electronically through the ND Health Enterprise MMIS
• Procedure Code: S5135 (Companion care, adult) is typically used, billed in 15-minute units
• Rate Setting: Rates are established by the ND HHS Medical Services Division and published in the official QSP Rate Schedule
• Prior Authorization: All services must be prior-authorized by the participant's regional HCBS Case Manager before delivery
• Payment Source: Payments are issued directly by North Dakota Medicaid, not through managed care organizations

9. Approval Sequence and Timeline

The QSP enrollment process requires sequential completion of competency verification, background checks, and MMIS portal registration. Missing documentation at any step will halt the application.

Once the state approves the QSP enrollment, the provider must wait to receive specific client authorizations from regional case managers before beginning work.

• Step 1: Complete required QSP competency training or verify active ND CNA/nursing licensure
• Step 2: Submit fingerprint cards to ND BCI for background checks (typically takes 2 to 4 weeks)
• Step 3: Submit the QSP enrollment application and Medicaid Provider Agreement via ND Health Enterprise MMIS
• Step 4: ND HHS reviews the application and issues a QSP provider number (typically 30 to 60 days)
• Step 5: Receive client-specific service authorizations from regional HCBS Case Managers

10. Common Denials and Survey Findings

Applications are frequently delayed or denied due to incomplete background checks or missing competency documentation. The QSP enrollment unit will not process applications with illegible fingerprint cards.

Post-enrollment, providers often face claim denials if they fail to use the EVV system correctly or bill for services outside the authorized care plan.

• Background Check Delays: Failure to submit legible fingerprint cards to BCI causes immediate application stalling
• Competency Gaps: Submitting an application without proof of CNA licensure or completed QSP training modules results in denial
• EVV Non-Compliance: Failing to properly log visits in the state's EVV system leads to automatic claim denials
• Out-of-Scope Billing: Billing for hands-on medical care under the companionship code triggers recoupment
• Expired Revalidation: Failure to complete the mandatory five-year Medicaid revalidation results in provider deactivation

11. Key Contacts and Resources

Prospective providers should utilize the official North Dakota HHS portals for all application materials, handbooks, and rate schedules. The QSP enrollment unit is the primary point of contact for application status.

Regional Human Service Centers serve as the local hubs for HCBS Case Managers who authorize the actual companionship services.

• ND HHS QSP Enrollment Unit: https://www.hhs.nd.gov/healthcare/medicaid/provider/enrollment-information
• ND Health Enterprise MMIS: https://www.hhs.nd.gov/healthcare/medicaid/provider
• ND HCBS Waiver Information: https://www.hhs.nd.gov/aging
• ND Bureau of Criminal Investigation: https://attorneygeneral.nd.gov/law-enforcement/bureau-of-criminal-investigation

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