Oregon - Adult Companion Services — Licensing, Medicaid Enrollment and Startup Requirements
Last reviewed: 2026-09-10
In Oregon, Adult Companion Services are not licensed or enrolled as a standalone Medicaid provider type. Instead, non-medical supervision and socialization services are delivered as part of the broader Home and Community-Based Services (HCBS) system under the K Plan (Community First Choice) and the 1915(c) Aged and Physically Disabled (APD) Waiver, administered by the Oregon Department of Human Services (ODHS) Aging and People with Disabilities (APD) program.
Because Oregon does not issue a distinct "Adult Companion Services" license, providers offering these supports must enroll as an approved HCBS provider—such as an In-Home Care Agency or an Adult Day Services (ADS) program—or operate as an individual homecare worker. The most significant structural prerequisite is that agency providers must obtain the underlying state licensure or certification for their specific facility or agency type (e.g., Adult Day Services certification) before they can execute a Medicaid Provider Enrollment Application and Agreement (PEA) with ODHS.
1. Service Definition and Scope
Oregon delivers non-medical supervision, socialization, and assistance with activities of daily living through its K Plan (Community First Choice state plan option) and the 1915(c) Aged and Physically Disabled (APD) Waiver. These services allow individuals who meet a nursing-facility level of care to remain safely in their own homes or community settings.
Rather than a standalone "Adult Companion" service, these supports are integrated into in-home care, attendant care, and adult day services. The services must be delivered according to a Person-Centered Service Plan developed by a case manager, ensuring they support the individual's health, safety, and personal goals without duplicating other services.
- Service Delivery: Provided in the individual's home, the home of a relative, or a certified community setting like an Adult Day Services program.
- Target Population: Individuals ages 65 or older, and individuals with physical disabilities ages 18 to 64 meeting nursing-facility level of care.
- Person-Centered Service Plan: Dictates the specific supports, outcomes, and activities required for the participant.
- Conflict of Interest: The person-centered service plan may not be developed by the provider of the HCBS services.
2. Regulatory and Oversight Agencies
The primary oversight body for aging and physical disability HCBS in Oregon is the Department of Human Services (ODHS), specifically the Aging and People with Disabilities (APD) program. ODHS APD manages provider certification, Medicaid enrollment, and compliance with HCBS settings rules.
The Centers for Medicare and Medicaid Services (CMS) provides federal oversight of the K Plan and the 1915(c) APD Waiver. Background checks for all provider staff are processed through the ODHS Background Check Unit (BCU).
- Agency: Oregon Department of Human Services (ODHS) Aging and People with Disabilities (APD) (https://www.oregon.gov/odhs/providers-partners/seniors-disabilities/pages/waivers-kplan.aspx)
- Federal Oversight: Centers for Medicare and Medicaid Services (CMS) (https://www.cms.gov/)
- Background Checks: ODHS Background Check Unit (BCU) (https://www.oregon.gov/odhs/providers-partners/pages/background-checks.aspx)
- Business Registration: Oregon Secretary of State Corporation Division (https://sos.oregon.gov/business/Pages/default.aspx)
3. Gatekeeping Prerequisites: Who Can Even Apply
Oregon does not have a standalone "Adult Companion" provider enrollment category. To provide these services and bill Medicaid, an entity must first be legally established and certified or licensed in Oregon for the specific modality they intend to operate, such as an Adult Day Services (ADS) program or a licensed In-Home Care Agency.
There is no Certificate of Need required for HCBS in-home or adult day services in Oregon. However, an applicant cannot submit a Medicaid Provider Enrollment Application and Agreement (PEA) without first holding the underlying certification (e.g., ADS certification) and an active business registration with the Oregon Secretary of State.
- Underlying Certification: Must hold current certification or licensure for the specific service type (e.g., Adult Day Services certification under OAR chapter 411, division 004) before Medicaid enrollment.
- Business Registration: Must have a current business registration and assumed business name (ABN), if applicable, with the Oregon Secretary of State.
- HCBS Settings Compliance: Must comply with the Oregon Statewide Transition Plan for HCBS settings, ensuring the setting integrates and supports full access to the community.
- No Standalone Category: Cannot apply simply as an "Adult Companion"; must apply under an established ODHS APD provider type.
4. Licensure and Certification Requirements
Because companion-type services are often delivered in Adult Day Services (ADS) settings or by In-Home Care Agencies, providers must meet the certification standards for those specific programs. For example, ADS programs are certified by ODHS APD to ensure they meet health, safety, and programmatic standards.
Certification involves submitting an application, passing an initial screening or survey, and demonstrating compliance with OAR chapter 411 rules. The certification measures the program's ability to meet DHS standards and must be kept current to maintain Medicaid enrollment.
- Rule Citation: Adult Day Services are governed by OAR chapter 411, division 004.
- Certification Definition: The process by which DHS APD measures and approves the program's ability to meet state standards.
- Disclosure Statement: Must provide a statement describing the range of care, admission/discharge criteria, and fee arrangements.
- Activity Plan: Must develop an activity plan based on the interests, needs, and abilities of the participants.
5. Medicaid Provider Enrollment
Once certified or licensed, the provider must enroll with ODHS APD to receive a Medicaid Performing Provider Number. This number is required to receive service authorizations and submit claims for Medicaid-funded HCBS under the K Plan or 1915(c) waiver.
Enrollment requires completing the Adult Day Services (or applicable) Medicaid Provider Enrollment Application and Agreement (PEA). Providers must maintain required insurance and comply with all Medicaid rules to avoid termination of their provider number.
- Application: Must complete the Medicaid Provider Enrollment Application and Agreement (PEA) upon initial enrollment and renewal.
- Required Documents: Must provide a copy of the current certification and business registration.
- Provider Number: Issuance of a Medicaid Performing Provider Number is required for identification and billing.
- Insurance: Must maintain the insurance requirements as defined in the PEA.
6. Staffing, Training and Background Checks
All staff and volunteers providing HCBS in Oregon must pass strict background checks and meet minimum qualifications. The ODHS Background Check Unit processes these checks to ensure participant safety.
Program directors for certified settings like ADS must meet specific age and educational or experience requirements. Additionally, staff involved in food service must hold appropriate food handler certifications, and all staff must be trained as mandatory reporters of abuse.
- Background Checks: All employees and volunteers must comply with criminal history and abuse check rules in OAR 407-007-0200 through 407-007-0380.
- Program Director Qualifications: Must be at least 21 years old and have either a Bachelor's degree in health care/management OR a high school diploma with at least two years of relevant experience in the past five years.
- Mandatory Reporters: All staff are mandatory reporters of suspected abuse or neglect under ORS 124.050 - 124.095 and OAR 411-020-0002.
- Food Handlers: Staff involved in food preparation or service must be licensed under ORS 624.020 or 624.320.
7. Documentation, Policies and Records
Providers must maintain comprehensive records for each participant, including medical information, service plans, and progress notes. Documentation must be kept current and available for review by ODHS or the Oregon Health Authority.
Agencies must have written policies covering everything from medication administration to emergency transportation. Failure to maintain these records or provide them to designated state entities can result in termination of Medicaid enrollment.
- Medical Information: Must obtain and document medical info (physician contacts, medications, advance directives) and review it semi-annually.
- Progress Notes: Must be written at least quarterly, reflecting a review of the participant's service plan.
- Medication Policy: Must have a written policy designating which staff are trained and authorized to administer medications.
- Employment Procedures: Must have written procedures to evaluate and determine employment status based on criminal background findings.
8. Billing, Rates and Claims
Medicaid reimbursement for HCBS under the K Plan and 1915(c) waiver is governed by the Medicaid reimbursement rate schedule maintained by ODHS. Providers bill using their assigned Medicaid Performing Provider Number.
Services must be prior-authorized by the participant's case manager and included in the Person-Centered Service Plan. Providers cannot bill for services that duplicate those provided by another agency or facility.
- Rate Schedule: Maintained by the Department in OAR 411-027-0170.
- Billing Identifier: Claims are submitted using the Medicaid Performing Provider Number.
- Authorization: Services must be authorized by a Case Manager (CM) based on the Person-Centered Service Plan.
- Coordination of Care: Service plans must acknowledge and not duplicate services provided by other agencies.
9. Approval Sequence and Timeline
Becoming an HCBS provider in Oregon is a multi-step process. An entity must first establish its business, obtain the necessary facility or agency certification from ODHS APD, and then apply for Medicaid enrollment.
While specific timelines for provider enrollment vary, the state is bound by federal rules regarding participant eligibility determinations (45 to 90 days). Providers should expect the certification and background check processes to take several weeks to months before they can execute the PEA.
- Step 1: Register the business with the Oregon Secretary of State.
- Step 2: Apply for and obtain the underlying certification (e.g., Adult Day Services certification) from ODHS APD.
- Step 3: Ensure all staff clear the ODHS Background Check Unit process.
- Step 4: Submit the Medicaid Provider Enrollment Application and Agreement (PEA) with proof of certification and insurance.
10. Common Denials and Survey Findings
Medicaid provider enrollment can be denied or terminated if an agency fails to maintain its underlying certification or violates ODHS rules. Compliance with background check requirements and abuse reporting is strictly enforced.
During surveys or audits, common findings include incomplete participant records, failure to update medical information semi-annually, or lack of required progress notes. Providers may appeal terminations based on OAR 407-120-0360.
- Certification Lapse: Failure to keep required certifications current is grounds for termination.
- Background Check Failures: Non-compliance with OAR 407-007-0200 through 407-007-0370 will result in denial or termination.
- Record Keeping: Failure to provide copies of required records to ODHS or OHA entities.
- Abuse Rules: Violation of protective service and abuse rules in OAR chapter 411, division 020.
11. Key Contacts and Resources
Prospective providers should utilize ODHS resources to understand certification and enrollment requirements. The ODHS APD website provides access to rules, forms, and transition plan details.
For specific questions regarding HCBS compliance or the K Plan, providers can contact the state directly via designated email addresses or local APD offices.
- ODHS HCBS Provider Resources: https://www.oregon.gov/odhs/providers-partners/pages/hcbs.aspx
- ODHS APD Waivers and K Plan: https://www.oregon.gov/odhs/providers-partners/seniors-disabilities/pages/waivers-kplan.aspx
- Oregon Administrative Rules (OARs): https://secure.sos.state.or.us/oard/
- HCBS Transition Plan Contact: [email protected]
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