Texas - Skilled Nursing Services — Licensing, Medicaid Enrollment and Startup Requirements
Last reviewed: 2026-08-16
In Texas, providing Medicaid Home and Community-Based Services (HCBS) Skilled Nursing requires obtaining a Home and Community Support Services Agency (HCSSA) license from the Texas Health and Human Services Commission (HHSC) and enrolling as a Medicaid provider through the Texas Medicaid & Healthcare Partnership (TMHP). The service encompasses skilled interventions, comprehensive assessments, and medication administration delivered in the home by Registered Nurses (RNs) and Licensed Vocational Nurses (LVNs) under direct physician orders.
The single biggest structural barrier to entry for this service in Texas is securing network contracts with STAR+PLUS Managed Care Organizations (MCOs) or passing the mandatory Provider Applicant Training (PAT) and competency exams for the Home and Community-based Services (HCS) waiver open enrollment. Because Texas Medicaid HCBS is heavily managed, holding an HCSSA license and TMHP enrollment does not guarantee the ability to bill; providers must be accepted into regional MCO networks, which frequently close to new providers based on network adequacy.
1. Service Definition and Scope
Skilled Nursing Services in Texas HCBS are defined as complex medical care, assessments, and treatments provided in a client's residence by licensed nursing professionals. These services must be medically necessary, ordered by a physician, and delivered in accordance with the Texas Nursing Practice Act.
Under Texas Medicaid waivers like STAR+PLUS and HCS, nursing services are utilized to prevent institutionalization. RNs handle comprehensive assessments, care planning, and delegation, while LVNs (Texas uses the term LVN rather than LPN) provide routine treatments and medication administration under RN supervision.
- Service Category: Skilled Nursing Services under STAR+PLUS, HCS, and Texas Home Living (TxHmL) waivers
- Provider Type: Home and Community Support Services Agency (HCSSA) with a Home Health category
- RN Duties: Comprehensive health assessments, care plan development, complex skilled treatments, and LVN/aide delegation
- LVN Duties: Medication administration, routine wound care, and patient monitoring under the clinical supervision of an RN
- Physician Orders: Required for all skilled nursing interventions and must be updated and signed at least every 60 days per Title 26 TAC §558.402
- Setting: Services must be delivered in the client's home or community setting, adhering to the HCBS Settings Final Rule
2. Regulatory and Oversight Agencies
The Texas Health and Human Services Commission (HHSC) is the primary regulatory body responsible for licensing HCSSAs and overseeing Medicaid waiver programs. HHSC conducts initial and routine health and safety surveys to ensure compliance with state regulations.
The Texas Medicaid & Healthcare Partnership (TMHP) acts as the state's Medicaid claims administrator and handles all provider enrollment. Nursing professionals themselves are regulated by the Texas Board of Nursing (BON).
- Licensing Agency: Texas Health and Human Services Commission (HHSC) (https://www.hhs.texas.gov)
- Licensing Portal: Texas Unified Licensure Information Portal (TULIP) (https://txhhs.force.com/TULIP/s/login/)
- Medicaid Enrollment: Texas Medicaid & Healthcare Partnership (TMHP) (https://www.tmhp.com)
- Enrollment Portal: Provider Enrollment and Management System (PEMS) (https://www.tmhp.com/topics/provider-enrollment)
- Nursing Board: Texas Board of Nursing (BON) (https://www.bon.texas.gov)
- Managed Care Oversight: HHSC Medicaid and CHIP Services (MCS) division (https://www.hhs.texas.gov/services/health/medicaid-chip)
3. Gatekeeping Prerequisites: Who Can Even Apply
Texas does not have a Certificate of Need (CON) program or a state-wide moratorium for home health or HCSSA licensure. Any entity that meets the financial and structural requirements can apply for an HCSSA license through HHSC.
However, strict structural gates exist for Medicaid billing. To serve STAR+PLUS members, providers must secure contracts with regional MCOs (such as Superior HealthPlan or Molina Healthcare), which frequently enforce closed networks based on regional adequacy. To serve HCS or TxHmL waiver participants, applicants must pass the HHSC Open Enrollment process, which strictly requires completing the Provider Applicant Training (PAT) course and passing an in-person competency exam before an application is even accepted.
- Certificate of Need: None exists in Texas for home health or HCSSA licensure
- STAR+PLUS MCO Contracting: Required to bill managed care; MCOs may close networks to new providers based on regional adequacy assessments
- HCS/TxHmL Open Enrollment: Requires completion of the Provider Applicant Training (PAT) course and an in-person competency exam before applying (26 TAC §52.31)
- Medicare Enrollment Prerequisite: Often required by TMHP for traditional Medicaid home health enrollment, though waiver-only providers may seek specific exemptions
- Physical Location: Must have a physical operating location in Texas (not a virtual address or P.O. Box) before PEMS enrollment is permitted
4. Licensure and Certification Requirements
To provide skilled nursing in the home, an agency must obtain a Home and Community Support Services Agency (HCSSA) license from HHSC. The agency must select the Licensed Home Health Services (LHHS) or Licensed and Certified Home Health Services (L&CHHS) category on their application.
The licensure process is managed entirely online through the TULIP portal. Before applying, the designated Administrator and Alternate Administrator must complete specific state-mandated training modules.
- License Type: HCSSA License with LHHS or L&CHHS category (26 TAC §558.1)
- Application Portal: TULIP (Texas Unified Licensure Information Portal)
- Initial Training: Administrator and Alternate Administrator must complete 24 hours of initial HCSSA training (Modules 1, 2, and 3) and upload certificates to TULIP
- Application Fee: $1,750 for an initial HCSSA license payable to HHSC
- Survey Requirement: Must pass an initial on-site health and safety survey by HHSC after admitting and providing services to at least one client
- Renewal: HCSSA licenses must be renewed every three years through TULIP
5. Medicaid Provider Enrollment
Once the HCSSA license is active, the agency must enroll in Texas Medicaid through TMHP's Provider Enrollment and Management System (PEMS). Enrollment is mandatory before an agency can contract with STAR+PLUS MCOs or bill for waiver services.
Providers must ensure that all demographic data, physical addresses, and ownership information in PEMS exactly match the data on their HCSSA license and National Provider Identifier (NPI) registry.
- Enrollment System: TMHP Provider Enrollment and Management System (PEMS)
- Application Fee: $730 (CY 2025/2026) federal application fee for institutional providers, unless waived via proof of recent Medicare enrollment payment
- NPI Requirement: Must obtain a Type 2 (Organizational) NPI from NPPES before starting the PEMS application
- Taxonomy Code: Must use an appropriate Home Health taxonomy (e.g., 251E00000X) that aligns with the HCSSA license category
- Risk Category: Home health agencies are categorized as moderate or high risk, requiring fingerprint-based background checks for all 5% or greater owners
- Ownership Disclosure: Must complete detailed ownership and control disclosures per 42 CFR §455.104
6. Staffing, Training and Background Checks
Texas HCSSA regulations require agencies to maintain a specific administrative and clinical hierarchy. This includes a qualified Administrator to oversee operations and a Supervising Nurse to oversee all clinical services.
All patient-facing staff and owners must undergo rigorous background screening. Texas mandates checks through the Department of Public Safety (DPS) and specific state registries to ensure patient safety.
- Supervising Nurse: Must be a Texas-licensed RN with at least one year of nursing experience within the last 36 months
- Field Staff: RNs and LVNs must hold active, unencumbered licenses from the Texas Board of Nursing or a Nurse Licensure Compact state
- Background Checks: Fingerprint-based criminal history checks required for all owners (5%+) and direct care staff via the Texas Department of Public Safety (DPS)
- Registry Checks: Must verify staff against the Texas Employee Misconduct Registry (EMR) and Nurse Aide Registry (NAR) before hire and annually
- Administrator Training: 12 hours of continuing education required annually for the Administrator and Alternate Administrator
- CPR Certification: All nursing staff performing direct patient care must maintain current in-person CPR certification
7. Documentation, Policies and Records
HCSSAs must adhere to strict clinical and administrative record-keeping standards outlined in 26 TAC Chapter 558. Agencies must maintain comprehensive policies covering patient rights, infection control, and emergency preparedness.
Clinical records must clearly demonstrate medical necessity, adherence to physician orders, and the specific skilled interventions performed during each visit.
- Client Records: Must include comprehensive assessments, physician orders, care plans, and detailed clinical notes for every nursing visit
- Physician Orders: Must be signed and dated by the physician before billing and updated at least every 60 days
- Emergency Preparedness: Must maintain a comprehensive emergency preparedness and response plan tailored to the patient population (26 TAC §558.256)
- Quality Assessment: Must implement an ongoing Quality Assessment and Performance Improvement (QAPI) program
- Record Retention: Clinical and administrative records must be retained for a minimum of five years after the client's discharge or termination of services
- Policy Manual: Must maintain written policies on medication administration, delegation of nursing tasks, and abuse/neglect reporting
8. Billing, Rates and Claims
Billing procedures depend on the specific Medicaid program. For traditional fee-for-service or specific waivers like HCS, claims are submitted through TMHP's TexMedConnect. For STAR+PLUS, claims are submitted directly to the contracted MCO's clearinghouse.
Nursing services require prior authorization, and rates are established by HHSC. Providers must also comply with Electronic Visit Verification (EVV) mandates where applicable to in-home services.
- Billing System (FFS): TexMedConnect via the TMHP portal for traditional Medicaid and certain waiver claims
- Billing System (Managed Care): Claims submitted directly to the contracted STAR+PLUS MCO (e.g., via the Availity portal for Molina or Superior)
- Procedure Codes: Typically billed using HCPCS codes such as G0299 (RN services), G0300 (LVN services), or T1002/T1003 for waiver nursing
- Prior Authorization: Required for almost all skilled nursing visits under STAR+PLUS and HCBS waivers before services are rendered
- EVV Requirement: Electronic Visit Verification (EVV) is required for in-home personal care and specific home health services per HHSC mandates
- Rate Setting: Reimbursement rates are published on the HHSC Provider Finance Department website and may vary slightly by MCO contract
9. Approval Sequence and Timeline
Becoming a fully approved and billing Medicaid Skilled Nursing provider in Texas is a lengthy process, typically taking 6 to 12 months. The sequence requires sequential approvals from HHSC licensing, TMHP enrollment, and finally MCO contracting.
Providers cannot expedite the TMHP enrollment or MCO contracting phases, and any errors in the TULIP or PEMS applications will result in significant delays.
- Step 1: Administrator and Alternate Administrator complete 24-hour HCSSA training (1-2 weeks)
- Step 2: Submit HCSSA application via TULIP and pay $1,750 fee; HHSC review takes 45-90 days
- Step 3: Admit first patient and pass HHSC initial on-site health and safety survey (3-6 months)
- Step 4: Submit Medicaid enrollment application via TMHP PEMS; processing takes 60-120 days
- Step 5: Apply for network contracts with regional STAR+PLUS MCOs; credentialing takes 90-180 days subject to network adequacy
- Step 6: Obtain prior authorizations and commence Medicaid billing
10. Common Denials and Survey Findings
Applications and surveys frequently fail due to administrative oversights and documentation errors. HHSC surveyors strictly enforce the requirement that all skilled nursing interventions have corresponding, signed physician orders.
In the PEMS enrollment phase, TMHP routinely rejects applications where the physical address or ownership data does not perfectly match the Secretary of State, NPPES, and TULIP records.
- Licensure Denial: Failure of the Administrator to complete the exact required 24-hour training modules prior to TULIP submission
- PEMS Rejection: Physical address on the application does not exactly match the address on the HCSSA license or NPPES registry
- Survey Citation: Failure to obtain signed physician orders before initiating skilled nursing treatments (26 TAC §558.402)
- Survey Citation: Incomplete or missing emergency preparedness plans, or failure to conduct required emergency drills
- Claim Denial: Billing for services without an active prior authorization on file with the MCO
- Claim Denial: Failure to capture required Electronic Visit Verification (EVV) data for mandated in-home visits
11. Key Contacts and Resources
Providers should rely on official state portals and agency websites for the most current regulations, fee schedules, and training requirements. The HHSC and TMHP websites are the primary hubs for HCSSA and Medicaid information.
For managed care contracting, providers must contact the provider relations departments of the specific STAR+PLUS MCOs operating in their target service areas.
- HHSC HCSSA Licensing: https://www.hhs.texas.gov/providers/long-term-care-providers/home-community-support-services-agencies-hcssa
- TULIP Portal: https://txhhs.force.com/TULIP/s/login/
- TMHP Provider Enrollment (PEMS): https://www.tmhp.com/topics/provider-enrollment
- Texas Board of Nursing: https://www.bon.texas.gov
- STAR+PLUS Program Info: https://www.hhs.texas.gov/services/health/medicaid-chip/medicaid-chip-members/starplus
- HHSC Provider Finance Department: https://pfd.hhs.texas.gov
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