Ohio - Personal Emergency Response System — Licensing, Medicaid Enrollment and Startup Requirements
Last reviewed: 2026-08-16
In Ohio, a Personal Emergency Response System (PERS) is defined under Ohio Administrative Code (OAC) 5160-44-16 as a service providing a direct telephonic or electronic communications link between a waiver participant and a 24-hour response center. This service includes the installation, testing, and monthly monitoring of wearable or installed equipment designed to secure immediate assistance for individuals who live alone or are at high risk of falls.
The single biggest structural barrier to entry for a new PERS provider in Ohio is securing dual approval through both the Ohio Department of Aging (ODA) for certification and the Ohio Department of Medicaid (ODM) for financial enrollment, followed immediately by the mandatory requirement to credential and contract with regional MyCare Ohio managed care plans. Without active contracts with these managed care organizations, a fully licensed and enrolled provider will receive virtually no referrals in most regions of the state.
1. Service Definition and Scope
Under Ohio Administrative Code (OAC) 5160-44-16, PERS is an authorized Home and Community-Based Services (HCBS) waiver service. It provides a continuous electronic communications link to a response center for individuals enrolled in waivers such as PASSPORT, the Ohio Home Care Waiver, or MyCare Ohio.
The scope of the service mandates that providers not only supply the equipment but also manage the installation, ongoing maintenance, monthly testing, and the execution of a personalized written response plan for every participant.
- Equipment Standards: All deployed electronic devices must meet Underwriters Laboratories (UL) safety standards, and all telephonic devices must comply with Federal Communications Commission (FCC) regulations.
- Response Center Operations: The provider must operate or contract with a response center that is staffed and capable of receiving alarm signals 24 hours a day, 365 days a year.
- Written Response Plan: Providers must develop and maintain a written plan for each individual that includes their medical diagnosis, treatment preferences, and the contact information for designated responders.
- Monthly Testing: Providers are required to conduct and document a successful monthly test of the PERS equipment directly with the individual.
- Responder Notification: The provider must notify the individual's designated responders annually, and immediately upon any activation of the alarm, providing instructions on how to respond.
- Emergency Personnel Designation: Emergency service personnel (e.g., 911) are only identified as the primary responder on the written plan if the individual cannot designate at least two personal responders.
2. Regulatory and Oversight Agencies
PERS providers in Ohio are jointly overseen by the Ohio Department of Medicaid (ODM) and the Ohio Department of Aging (ODA). ODM handles the overarching Medicaid enrollment and the Ohio Home Care Waiver, while ODA specifically certifies providers for the PASSPORT waiver.
Additionally, ODM contracts with a third-party vendor to process HCBS applications, and delegates day-to-day care management for dual-eligible individuals to regional managed care plans.
- Ohio Department of Medicaid (ODM): Administers the state Medicaid program, manages the provider enrollment portal, and oversees the Ohio Home Care Waiver (https://medicaid.ohio.gov).
- Ohio Department of Aging (ODA): Evaluates and certifies providers for participation in the PASSPORT waiver program (https://aging.ohio.gov).
- Public Consulting Group (PCG): The contracted vendor responsible for processing ODM provider applications, verifying OAC compliance, and offering enrollment support (https://ohiohcbs.pcgus.com).
- Provider Network Management (PNM): The official ODM electronic portal where all provider enrollment applications and updates must be submitted (https://ohpnm.omes.maximus.com).
- MyCare Ohio Plans: Managed care organizations (e.g., Molina, CareSource, Aetna) that oversee care for dual-eligible members and require separate network contracts (https://medicaid.ohio.gov/families-and-individuals/citizen-programs-and-initiatives/mycareohio/mycare-ohio).
3. Gatekeeping Prerequisites: Who Can Even Apply
Ohio does not require a Certificate of Need (CON), Facility Need Review, or a competitive Request for Proposals (RFP) to become a PERS provider. The state operates an open enrollment network for Medicaid fee-for-service.
However, strict structural prerequisites exist before an application can be successfully processed, primarily revolving around equipment certification and managed care network access.
- No Certificate of Need: Ohio explicitly does not require a CON or regional need-review approval prior to applying to be a PERS provider.
- Business Entity Registration: Applicants must be legally organized entities registered and in good standing with the Ohio Secretary of State.
- Managed Care Contracting: While state Medicaid enrollment is open, serving the majority of the waiver population requires securing active contracts with regional MyCare Ohio Managed Care Organizations (MCOs), which may close their networks based on regional adequacy.
- Equipment Certification Proof: Applicants must possess and be ready to submit proof that all deployed electronic devices meet UL Standards and telephonic devices meet FCC regulations prior to service delivery.
- Medicaid Exclusion Checks: Owners and managing employees must not appear on the federal OIG List of Excluded Individuals/Entities (LEIE) or the Ohio Medicaid Provider Exclusion and Suspension List.
4. Licensure and Certification Requirements
Ohio does not issue a distinct "PERS License" through the Department of Health. Instead, providers must obtain ODA Certification to serve older adults and ODM approval to serve the broader waiver population.
This certification process requires attesting to specific administrative rules and defining the exact geographic footprint the provider intends to serve.
- ODA Certification: Required for PASSPORT waiver services; applied for concurrently via the PNM system under OAC 173-39-03.
- Rule Compliance Attestation: Providers must formally attest to compliance with OAC 173-39-02 (General ODA provider requirements) and OAC 173-39-02.6 (PERS specific requirements).
- Service Area Designation: Applicants must explicitly define their requested county-by-county service area during the certification process; billing outside this area is prohibited.
- W-9 Form: Must submit a current, signed IRS Form W-9 matching the legal business name registered with the Secretary of State.
- Liability Insurance: Must maintain commercial general liability insurance (typically $1 million per occurrence and $2 million aggregate) as required by general waiver provider rules.
5. Medicaid Provider Enrollment
All enrollment is conducted electronically through the Provider Network Management (PNM) system. Ohio does not accept paper applications for Medicaid enrollment.
The application routes through Public Consulting Group (PCG) for HCBS compliance verification before final approval by ODM.
- OHID Creation: The provider administrator must first create an OHID account to access the PNM system and initiate a new application.
- Application Type: Applicants must select "Medicaid Waiver (ODM)" or the specific ODA certification track within the PNM portal.
- Provider Type Selection: Must enroll under the specific Provider Type code designated for PERS/Assistive Devices (historically PT 55 or waiver-specific codes).
- Application Fee: Subject to the federal Medicaid institutional provider application fee (approximately $731 for 2024) unless waived by proof of Medicare enrollment or another state's Medicaid program enrollment.
- PCG Review: Submitted applications are routed to Public Consulting Group (PCG) to verify that applicants meet the provider qualifications outlined in the Ohio Administrative Code.
6. Staffing, Training and Background Checks
While PERS does not require in-home nursing or direct personal care staff, the personnel installing the equipment and operating the 24-hour response center must meet strict background and training standards.
Ohio mandates specific routing for criminal background checks to ensure state oversight of all waiver service personnel.
- BCI Background Checks: All owners and employees must undergo an Ohio Bureau of Criminal Identification and Investigation (BCI) background check via the electronic WebCheck system.
- Direct Routing Requirement: BCI results must be sent directly from the WebCheck vendor to ODM (Attn: BCI Coordinator, P.O. Box 183017 4th Floor, Columbus, OH 43218-3017); results sent to the provider are invalid.
- Response Center Staffing: The provider must maintain sufficient trained staff to operate the emergency response center 24/7/365 without interruption.
- Installer Training: Staff installing equipment must be trained on the specific UL/FCC-approved devices and instructed on how to conduct the initial successful test with the participant.
- First Aid/CPR Exemption: Unlike personal care aides, PERS installers generally do not require hands-on First Aid/CPR certification, but must be trained in emergency escalation protocols.
7. Documentation, Policies and Records
Providers must maintain comprehensive records for each waiver participant, subject to audit by ODM, ODA, PCG, or managed care designees.
Failure to maintain these records, particularly the testing logs and response plans, is a primary cause for recoupment of funds.
- Written Response Plan File: Must keep a file for each individual detailing medical history, treatment preferences, and designated responders, updated at least annually.
- Testing Logs: Must maintain documented evidence of the initial successful test upon installation and all subsequent monthly tests conducted with the participant.
- Incident Reporting: Must comply with the Adult Incident Reporting System (AIRS) and notify the waiver case manager within 24 hours of any critical incident or emergency dispatch.
- Service Delivery Records: Must keep exact records of installation dates, maintenance visits, and equipment retrieval dates to justify billing.
- Record Retention: All Medicaid and waiver service records must be retained for a minimum of six years, or longer if an audit is pending.
8. Billing, Rates and Claims
PERS is reimbursed on a fee-for-service basis for traditional waiver participants or via contracted rates with MyCare Ohio plans. Claims are processed through the Ohio Medicaid Enterprise System (OMES).
Because PERS is an equipment and monitoring service rather than an in-home personal care service, it is generally exempt from Electronic Visit Verification (EVV) requirements.
- Billing Codes: Typically billed using HCPCS code S5160 for initial installation and S5161 for the ongoing monthly service and monitoring fee.
- Prior Authorization: All PERS services require prior authorization and must be explicitly included in the individual's person-centered services plan by their case manager before installation.
- OMES Portal: Fee-for-service claims are submitted electronically via the PNM/OMES portal or through an approved clearinghouse.
- MCO Billing: Claims for MyCare Ohio members must be submitted directly to the respective managed care plan (e.g., Molina, CareSource) following their specific timely filing limits.
- EVV Exemption: PERS providers do not need to log visits in the state's Sandata EVV system, as the service does not meet the definition of direct personal care.
9. Approval Sequence and Timeline
The end-to-end process from application to active billing status typically takes 3 to 6 months. This timeline is heavily dependent on the completeness of the initial application and the speed of managed care credentialing.
Providers cannot bill for services provided prior to their official Medicaid effective date and the authorization date on the participant's care plan.
- Step 1: OHID Registration: Create an OHID and access the PNM portal (1-2 days).
- Step 2: BCI Background Check: Complete WebCheck fingerprinting and wait for results to reach the ODM BCI Coordinator (2-4 weeks).
- Step 3: PNM Application Submission: Complete the online application and upload the W-9, insurance, and equipment certifications (1 week).
- Step 4: PCG/ODA Review: Public Consulting Group and ODA review the application for compliance and service area approval (30-60 days).
- Step 5: Medicaid Welcome Letter: Receive the official Medicaid ID and effective date via the PNM system.
- Step 6: MCO Credentialing: Apply for network participation and credentialing with regional MyCare Ohio plans (an additional 60-90 days).
10. Common Denials and Survey Findings
Applications and ongoing certifications are frequently delayed or denied due to administrative errors or failure to maintain required documentation.
State surveyors and PCG reviewers strictly enforce the monthly testing and background check routing rules.
- BCI Routing Errors: Applications are frequently delayed because BCI background check results were sent to the provider's office instead of directly to the ODM BCI Coordinator.
- Missing Equipment Specs: Denials occur when applicants fail to upload proof that their specific PERS devices meet UL and FCC standards.
- Lapsed Monthly Testing: Surveyors frequently cite providers for failing to document the required monthly test of the PERS equipment with the participant.
- Incomplete Response Plans: Citations are common for missing designated responder contact information or failing to update the written response plan annually.
- Unapproved Service Areas: Providers face recoupment for billing services provided to a participant residing in a county not explicitly approved on their ODA certification.
11. Key Contacts and Resources
Prospective providers should utilize the following official state resources for application submission, regulatory guidance, and technical support.
Always ensure you are accessing the official .gov or state-contracted vendor portals when submitting sensitive business information.
- Ohio Department of Medicaid (ODM): Official state Medicaid agency homepage (https://medicaid.ohio.gov).
- Ohio Department of Aging (ODA) Certification: Guidelines and rules for PASSPORT certification (https://aging.ohio.gov/agencies-and-service-providers/certification).
- Provider Network Management (PNM) Portal: The required system for all enrollment applications (https://ohpnm.omes.maximus.com).
- Public Consulting Group (PCG): HCBS enrollment support and application processing vendor (https://ohiohcbs.pcgus.com).
- Ohio Medicaid Integrated Helpdesk (IHD): Contact at 1-800-686-1516 for PNM technical assistance and enrollment routing.
- Ohio Attorney General WebCheck Locations: Directory of approved fingerprinting vendors for BCI checks (http://www.ag.state.oh.us/business/fingerprint/data/index.asp).
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