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

Last reviewed: 2026-08-16

In Texas, Transition Assistance Services (TAS) helps Medicaid-eligible individuals residing in nursing facilities set up a household in the community upon discharge. The service covers one-time set-up expenses and coordination for individuals enrolling in the Community Living Assistance and Support Services (CLASS), Deaf Blind with Multiple Disabilities (DBMD), Medically Dependent Children Program (MDCP), or STAR+PLUS Home and Community Based Services (HCBS) waiver programs, as detailed by the Texas Health and Human Services Commission in [Transition Assistance Services (TAS)](https://www.hhs.texas.gov/providers/long-term-care-providers/transition-assistance-services-tas).

The single biggest structural barrier to entry for a prospective TAS provider in Texas is the dual-layered contracting requirement. Providers cannot simply enroll in Medicaid; they must first secure a noncompetitive Open Enrollment contract directly with the Texas Health and Human Services Commission (HHSC) and, to serve the largest population (STAR+PLUS), subsequently secure closed-network contracts with regional Managed Care Organizations (MCOs).

1. Service Definition and Scope

TAS provides funding and coordination for one-time set-up costs to move a person out of an institution and into their own community home. The service is coordinated prior to discharge, with goods and services delivered upon or immediately after the individual's transition to the community.

Allowable expenses are strictly limited to essential household items and services required to establish a basic living arrangement. TAS does not cover ongoing expenses, luxury items, or services already provided by other waiver benefits.

• Target Population: Medicaid-eligible individuals discharging from a nursing facility into a community waiver program.
• Covered Waivers: CLASS, DBMD, MDCP, and STAR+PLUS HCBS.
• Allowable Expenses: Security deposits, utility set-up fees, essential household furnishings, and moving expenses.
• Excluded Expenses: Monthly rental or mortgage payments, food, ongoing utility charges, and recreational electronics.
• Service Timing: Coordination occurs before discharge; items are delivered upon or immediately after discharge.

2. Regulatory and Oversight Agencies

The Texas Health and Human Services Commission (HHSC) is the primary regulatory body, managing the Open Enrollment process, contract oversight, and policy development for TAS.

Texas Medicaid & Healthcare Partnership (TMHP) acts as the state's Medicaid fiscal agent, handling the provider enrollment portal and fee-for-service claims, while regional Managed Care Organizations oversee STAR+PLUS providers.

• Primary Regulator: Texas Health and Human Services Commission (HHSC) [https://www.hhs.texas.gov].
• Medicaid Fiscal Agent: Texas Medicaid & Healthcare Partnership (TMHP) [https://www.tmhp.com].
• Rulemaking Authority: Texas Secretary of State (Texas Administrative Code) [https://www.sos.state.tx.us].
• Managed Care Oversight: HHSC Managed Care Contract Management [https://www.hhs.texas.gov/services/health/medicaid-chip/provider-information/managed-care-contract-management].
• Designating Entity (STAR+PLUS): Superior HealthPlan [https://www.superiorhealthplan.com].
• Designating Entity (STAR+PLUS): Community First Health Plans [https://medicaid.communityfirsthealthplans.com].

3. Gatekeeping Prerequisites: Who Can Even Apply

Texas does not require a Certificate of Need for TAS, but it strictly controls access through the HHSC Open Enrollment process. A provider's application will not be accepted unless they meet foundational business and legal requirements.

Furthermore, access to the STAR+PLUS population is restricted by managed care plan contracting requirements; providers must be accepted into the networks of regional MCOs, which may have closed networks or specific procurement windows.

• Contracting Mechanism: HHSC Open Enrollment process (noncompetitive, year-round submission).
• Legal Entity Requirement: Must be a legal entity authorized to do business in Texas, evidenced by a Certificate of Formation filed with the Secretary of State.
• Physical Presence: Must maintain a physical business address within the state of Texas.
• Financial Standing: Must be in good standing with the Texas Comptroller of Public Accounts (active Franchise Tax Account Status).
• MCO Network Affiliation: Required credentialing and contracting with regional MCOs to serve STAR+PLUS members.

4. Licensure and Certification Requirements

Texas does not issue a distinct TAS License. Instead, providers are certified and approved through the HHSC Open Enrollment contracting process as outlined in [Transition Assistance Services (TAS)](https://www.hhs.texas.gov/providers/long-term-care-providers/transition-assistance-services-tas).

Providers must comply with specific state administrative rules governing the service and the contracting process, submitting a comprehensive application packet directly to the state office.

• Program Rules: Texas Administrative Code (TAC), Title 26, Part 1, Chapter 272 (Transition Assistance Services).
• Contracting Rules: TAC, Title 26, Part 1, Chapter 52 (Contracting for Community Care Services).
• Application Packet: Form 5830 (Application Packet Checklist, State Office Enrolled).
• Submission Destination: Mailed to HHSC Contract Administration and Provider Monitoring - Waiver Program Enrollments (Mail Code W-359).
• Business Registration: Assumed Business Name (DBA) certificate filed with the county or Secretary of State.

5. Medicaid Provider Enrollment

After meeting HHSC eligibility criteria, providers must enroll in Texas Medicaid to receive reimbursement. This is processed through the state's centralized enrollment system, as noted in [Provider Enrollment](https://www.tmhp.com/topics/provider-enrollment).

Enrollment requires standard federal identifiers, payment of an application fee, and execution of a state provider agreement, detailed in [How to Become a Medicaid Provider in Texas](https://www.suretybonds.com/guide/texas/medicaid-provider-license).

• Enrollment Portal: Provider Enrollment and Management System (PEMS) [https://www.tmhp.com/topics/provider-enrollment].
• Identifier: 10-digit National Provider Identifier (NPI) obtained from NPPES.
• Enrollment Fee: $730 provider enrollment fee for most applicants (as of 2025).
• Agreement: Execution of the written Texas Medicaid Provider Agreement with HHSC.
• Tax Documentation: Submission of IRS Form W-9 and Employer Identification Number (EIN) verification.

6. Staffing, Training and Background Checks

Because TAS is primarily an administrative and purchasing coordination service, it does not require clinical nursing staff. However, the agency must ensure its personnel are qualified and vetted.

Owners and key personnel are subject to strict background checks, and the agency must complete state-mandated training prior to providing services.

• Background Checks: Fingerprint-based criminal history checks required for all owners with 10% or more interest.
• Exclusion Screening: Monthly screening of staff against the Texas Health and Human Services Office of Inspector General (OIG) and federal LEIE databases.
• Staff Qualifications: Must have experience with or demonstrated capacity to administer services for vulnerable populations.
• Training Requirement: Completion of HHSC TAS provider training and orientation prior to contract execution.
• Subcontractors: Third-party vendors (e.g., moving companies) must be vetted by the provider but do not need separate Medicaid enrollment.

7. Documentation, Policies and Records

HHSC requires TAS providers to maintain comprehensive organizational policies and individual client records. Documentation is critical to prove that authorized funds were spent appropriately.

Providers must retain original financial records and proof of delivery to survive state audits and contract monitoring reviews.

• Organizational Policies: Must have written policies and procedures acceptable to HHSC for delivering TAS.
• Purchasing Records: Original receipts and invoices for all security deposits, furnishings, and moving expenses.
• Delivery Verification: Signed delivery logs confirming the waiver participant received the goods at their new community home.
• Record Retention: All financial and client records must be retained for a minimum of five years.
• Service Plans: Copies of the individual's authorized transition plan from the waiver case manager or MCO service coordinator.

8. Billing, Rates and Claims

TAS is billed as a one-time service upon the successful discharge of the individual into the community. Claims cannot be submitted while the individual remains in the nursing facility.

Billing pathways depend on the waiver program; fee-for-service claims go through the state portal, while managed care claims go to the respective MCO, as seen in [STAR+PLUS | Texas Health and Human Services](https://www.hhs.texas.gov/services/health/medicaid-chip/medicaid-chip-members/starplus).

• Billing System (FFS): TMHP TexMedConnect portal for CLASS, DBMD, and MDCP claims.
• Billing System (Managed Care): MCO-specific clearinghouses for STAR+PLUS claims.
• Reimbursement Structure: Actual cost up to the state-authorized maximum (historically capped per transition, typically $2,500).
• Prior Authorization: Services must be explicitly authorized on the Individual Plan of Care (IPC) or Individual Service Plan (ISP) before purchases are made.
• Claim Timing: Claims must be submitted only after the individual has physically discharged from the nursing facility.

9. Approval Sequence and Timeline

Becoming a fully operational TAS provider involves a sequential process of business formation, state contracting, Medicaid enrollment, and MCO credentialing.

The entire end-to-end process typically takes several months, heavily dependent on the provider's accuracy in submitting required forms.

• Step 1: Establish legal entity and obtain NPI (1-2 weeks).
• Step 2: Submit Form 5830 and Open Enrollment application to HHSC (60-90 days for review).
• Step 3: Complete PEMS enrollment via TMHP and pay the $730 fee (30-60 days).
• Step 4: Sign HHSC Community Care Services Contract (1-2 weeks).
• Step 5: Apply for MCO network credentialing for STAR+PLUS (90-120 days, often concurrent with PEMS).

10. Common Denials and Survey Findings

Applications are frequently delayed or denied due to incomplete packets or failure to respond to deficiency notices from HHSC or TMHP.

During contract monitoring, providers are most often cited for missing financial documentation or billing errors related to the transition date.

• Application Denial: Missing required legal entity documents (e.g., Certificate of Formation, Assumed Name Certificate).
• PEMS Rejection: Discrepancies between the legal name on the IRS W-9 and the PEMS application.
• Audit Finding: Failure to maintain original receipts for purchased household items.
• Audit Finding: Billing for TAS before the member's actual discharge date from the nursing facility.
• Audit Finding: Purchasing unallowable items (e.g., groceries, entertainment electronics) not approved on the transition plan.

11. Key Contacts and Resources

Prospective providers should utilize the official HHSC and TMHP websites for the most current forms, manuals, and rule citations.

The HHSC Waiver Program Enrollments unit is the primary point of contact for Open Enrollment application status and submission questions.

• HHSC Waiver Program Enrollments: 512-438-3234 (Mail Code W-359).
• HHSC Contracting Information: 512-438-3550.
• TMHP Provider Enrollment Help Desk: 800-925-9126 [https://www.tmhp.com].
• Texas Administrative Code (TAC) Viewer: [https://texreg.sos.state.tx.us/public/readtac$ext.viewtac].
• HHSC TAS Provider Page: [https://www.hhs.texas.gov/providers/long-term-care-providers/transition-assistance-services-tas].
• Provider Enrollment and Management System (PEMS): [https://www.tmhp.com/topics/provider-enrollment].

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