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Texas - Personal Assistance Services — Licensing, Medicaid Enrollment and Startup Requirements

Last reviewed: 2026-09-10

The Texas Health and Human Services Commission (HHSC) licenses agencies providing hands-on activities of daily living support as Home and Community Support Services Agencies (HCSSAs) under the Personal Assistance Services (PAS) category. Providers seeking Medicaid reimbursement must secure this HCSSA license through the Texas Unified Licensure Information Portal (TULIP) before applying to the Texas Medicaid & Healthcare Partnership (TMHP) Provider Enrollment and Management System (PEMS).

Medicaid reimbursement for PAS primarily flows through the STAR+PLUS managed care program and fee-for-service programs like Primary Home Care (PHC) and Community Attendant Services (CAS). Applicants must secure network contracts with regional Managed Care Organizations (MCOs), which frequently operate closed networks and only accept new PAS providers during targeted procurement windows or when network adequacy deficits are identified in specific counties.

1. Service Definition and Scope

In Texas, Personal Assistance Services (PAS) encompasses routine ongoing care or services required by an individual in a residence or independent living environment. HHSC defines this under 26 TAC §558.2 as hands-on assistance with activities of daily living (ADLs) such as bathing, dressing, grooming, feeding, exercising, toileting, positioning, and transferring.

PAS also includes delegated nursing tasks and health-related tasks under the supervision of a registered nurse, as well as assistance with instrumental activities of daily living (IADLs) like meal planning, housekeeping, and escorting to medical appointments.

2. Regulatory and Oversight Agencies

The Texas Health and Human Services Commission (HHSC) Long-Term Care Regulatory (LTCR) division is the primary licensing authority for HCSSAs. HHSC handles licensure applications, surveys, and enforcement through the TULIP system.

The Texas Medicaid & Healthcare Partnership (TMHP) acts as the state's Medicaid claims administrator and handles provider enrollment via PEMS. Managed Care Organizations (MCOs) oversee credentialing and authorization for the STAR+PLUS waiver.

3. Gatekeeping Prerequisites: Who Can Even Apply

Texas requires an active HCSSA license with a PAS category before a provider can enroll in Medicaid via TMHP. To obtain the initial HCSSA license, the agency administrator and alternate administrator must complete a mandatory pre-survey computer-based training (CBT) and submit the certificate with the application.

For Medicaid reimbursement, managed care contracting dictates market access. Most adult PAS is delivered through the STAR+PLUS program, requiring providers to secure contracts with regional MCOs (e.g., Superior HealthPlan, Amerigroup, Molina). MCOs frequently close their networks to new PAS providers unless there is a documented network adequacy need in a specific county.

4. Licensure and Certification Requirements

Agencies apply for an initial HCSSA license using Form 2021 through the TULIP system. The application requires detailed ownership disclosure, a designated Administrator and Alternate Administrator, and a physical office location in Texas that meets ADA requirements.

The initial license is valid for one year. During this period, the agency must pass an initial on-site health survey conducted by HHSC LTCR to verify compliance with 26 TAC Chapter 558. Subsequent renewal licenses are valid for three years.

5. Medicaid Provider Enrollment

Once licensed, the HCSSA must enroll as a Texas Medicaid provider through TMHP's Provider Enrollment and Management System (PEMS). The agency enrolls as a Long-Term Care (LTC) provider.

After PEMS enrollment, providers seeking to offer fee-for-service PAS (like Primary Home Care or Community Attendant Services) must complete a separate contracting process with HHSC. Providers targeting STAR+PLUS must apply directly to the MCOs in their service delivery area.

6. Staffing, Training and Background Checks

HCSSAs providing PAS must employ or contract with attendants who meet minimum qualifications under 26 TAC §558.288. Attendants must be at least 18 years old, or under 18 if a high school graduate or enrolled in a vocational program, and must demonstrate competency in the tasks assigned.

Agencies must conduct criminal history checks and registry clearances before an employee has direct contact with clients. A registered nurse (RN) must be available to supervise any delegated nursing tasks.

7. Documentation, Policies and Records

HCSSAs must maintain comprehensive written policies and procedures as mandated by 26 TAC §558.281. This includes client care policies, emergency preparedness plans, and infection control protocols.

Client records must document the individualized service plan, supervisory visits, and daily service delivery. For Medicaid reimbursement, Electronic Visit Verification (EVV) is mandatory for all PAS to record the date, time, and location of service delivery.

8. Billing, Rates and Claims

Medicaid PAS claims are processed either through TMHP for fee-for-service programs (PHC, CAS) or through the respective MCO for STAR+PLUS clients. All claims must be supported by matched EVV transaction data.

Rates for fee-for-service PAS are established by the HHSC Provider Finance Department. MCOs negotiate rates with providers, but they generally align with or exceed the HHSC fee schedule.

9. Approval Sequence and Timeline

The end-to-end process from forming an entity to billing Medicaid for PAS typically takes 9 to 18 months in Texas. The sequence begins with corporate formation and completion of the HCSSA pre-survey CBT.

After submitting the TULIP application, HHSC has 45 days to review and issue the initial license. The provider then enrolls in TMHP, admits a client, requests the initial survey, and finally applies for Medicaid contracts.

10. Common Denials and Survey Findings

HCSSA license applications are frequently delayed or denied due to incomplete ownership disclosures or failure to pass background checks for controlling persons. In TULIP, failure to respond to deficiency notices within the allotted timeframe results in application withdrawal.

During initial and renewal surveys, HHSC LTCR commonly cites agencies for administrative and operational deficiencies. Failure to properly implement EVV is a leading cause of Medicaid claim denials and recoupments.

11. Key Contacts and Resources

Providers must utilize official HHSC and TMHP resources for current rules, forms, and portal access. The Texas Administrative Code (TAC) Title 26, Part 1, Chapter 558 is the definitive rulebook for HCSSAs.

Regional HHSC LTCR offices handle survey scheduling and local compliance questions, while TMHP Provider Relations assists with PEMS enrollment issues.

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