Vermont - Adult Companion Services — Licensing, Medicaid Enrollment and Startup Requirements

Last reviewed: 2026-09-10

In Vermont, the Department of Disabilities, Aging, and Independent Living (DAIL) does not enroll standalone "Adult Companion Services" agencies; instead, non-medical supervision and socialization are funded as Companion Care through the Choices for Care (CFC) 1115 Waiver and delivered primarily by enrolled Home Care Providers or Adult Family Care (AFC) Authorized Agencies. Prospective organizations must first secure programmatic approval directly from the DAIL Adult Services Division (ASD) using the Home Care Provider Application before they are permitted to enroll in the state's Medicaid system.

Because there is no distinct companion-only license in Vermont, agencies must meet the broader CFC Universal Provider Qualifications and Standards. This requires submitting a comprehensive application packet to DAIL ASD that proves compliance with federal Home and Community-Based Settings (HCBS) rules, the DAIL Background Check Policy, and the capacity to maintain 24-hour emergency backup plans.

1. Service Definition and Scope

Vermont defines companion services under the Choices for Care (CFC) waiver as non-medical care, supervision, and socialization provided to a participant. This service is designed to assist adults with high, highest, or moderate needs to remain safely in their homes and communities.

Because Vermont bundles or categorizes these services under broader provider types, agencies deliver companion care as part of a Home Care Provider enrollment or within the shared living model managed by an Adult Family Care (AFC) Authorized Agency.

• Service Name: Companion Care (often bundled with Respite) under the Choices for Care (CFC) program.
• Funding Authority: Vermont Global Commitment to Health 1115 Waiver.
• Target Population: Vermont adults aged 18 and older with physical disabilities, and older adults aged 65 and over who meet nursing facility level of care.
• Scope of Service: Non-medical supervision, socialization, and assistance with daily living activities that do not require a licensed nurse.
• Excluded Activities: CFC shall not pay for services covered by other health insurance such as Medicare, VA, or private insurance.
• Delivery Models: Agency-based Home Care Providers, Adult Family Care (AFC) Authorized Agencies, or consumer-directed surrogate models.

2. Regulatory and Oversight Agencies

The primary oversight body for HCBS waiver services in Vermont is the Department of Disabilities, Aging, and Independent Living (DAIL), specifically its Adult Services Division (ASD). DAIL ASD is responsible for the initial programmatic review and approval of all new Choices for Care providers.

Once approved by DAIL, providers must enroll with the Department of Vermont Health Access (DVHA), which serves as the state Medicaid agency. Claims and provider enrollment processing are managed by Gainwell Technologies, Vermont's Medicaid fiscal agent.

• Programmatic Approver: DAIL Adult Services Division (ASD) (https://asd.vermont.gov/).
• Medicaid Authority: Department of Vermont Health Access (DVHA) (https://dvha.vermont.gov/).
• Fiscal Agent/MMIS: Vermont Medicaid Portal via Gainwell Technologies (https://vtmedicaid.com/).
• Background Check Authority: Vermont Agency of Human Services (AHS) Background Check Unit (https://humanservices.vermont.gov/).

3. Gatekeeping Prerequisites: Who Can Even Apply

Vermont strictly gates Medicaid enrollment for HCBS providers through a mandatory prior-approval process managed by DAIL ASD. A provider cannot simply submit a Medicaid enrollment application to Gainwell Technologies; they must first submit a Home Care Provider Application or AFC Authorized Agency Application to DAIL and receive an official approval letter.

There is no Certificate of Need (CON) required for non-medical home care in Vermont, nor are there closed enrollment windows for CFC Home Care Providers. However, the structural precondition is that the agency must meet the CFC Universal Provider Qualifications and agree to the DVHA Medicaid General Provider Agreement before DAIL will forward the approval to the fiscal agent.

• Standalone Companion Prohibition: Vermont does not enroll "Adult Companion Services" as a standalone provider type; applicants must apply as a Home Care Provider or AFC Authorized Agency.
• Prior Approval Requirement: Mandatory programmatic approval from DAIL ASD is required before a Medicaid application is accepted.
• Application Form: Must use the official DAIL "Home Care Provider Application" or "AFC Authorized Agency Provider Enrollment Application".
• HCBS Settings Rule: Applicants must attest to and demonstrate compliance with the Federal Home and Community-Based Setting (HCBS) Requirements.
• Business Registration: Must be registered and in good standing with the Vermont Secretary of State.

4. Licensure and Certification Requirements

Vermont does not require a specific state license for non-medical companion care agencies. Instead, the state relies on a certification and authorization process managed by DAIL ASD to ensure providers meet the Choices for Care program standards.

If an agency intends to provide skilled nursing or home health aide services alongside companion care, they must obtain a Home Health Agency designation from the Vermont Department of Health. For non-medical companion care only, the DAIL ASD Home Care Provider authorization serves as the operating credential.

• Licensure Exemption: Non-medical companion care does not require a Home Health Agency license in Vermont.
• DAIL Authorization: Serves as the functional equivalent of certification for CFC Home Care Providers.
• Universal Standards: Must comply with CFC Universal Provider Qualifications and Standards (Section III of the CFC program manual).
• Housing Safety: If operating an AFC model, must comply with the Vermont Housing Safety & Inspection Process Protocol.

5. Medicaid Provider Enrollment

After receiving the programmatic approval letter from DAIL ASD, the provider is instructed to submit a formal Medicaid Provider Enrollment application. This process is completed online through the Vermont Medicaid Provider Management Module managed by Gainwell Technologies.

Providers must sign the DVHA Medicaid General Provider Agreement and submit their DAIL approval documentation as an attachment to their Gainwell application. Failure to include the DAIL approval will result in immediate rejection by the fiscal agent.

• Enrollment Portal: Vermont Medicaid Provider Management Module (https://vtmedicaid.com/).
• Required Agreement: DVHA Medicaid General Provider Agreement.
• Prerequisite Documentation: Must upload the DAIL ASD approval letter.
• Application Fee: Subject to the CMS institutional provider application fee unless enrolled in Medicare or another state's Medicaid program.
• Revalidation: Providers must revalidate their Medicaid enrollment every five years.

6. Staffing, Training and Background Checks

All direct support workers providing companion care under the CFC waiver must pass comprehensive background checks before having direct contact with participants. Vermont enforces the DAIL Background Check Policy, which includes state and federal registries.

Agencies are responsible for ensuring that all staff receive adequate training to implement the participant's person-centered service plan. For AFC Authorized Agencies, this includes providing 24-hour on-call consultation and support to paid caregivers.

• Background Check Policy: Must comply with the DAIL Background Check Policy, including Adult Abuse Registry and Child Abuse Registry checks.
• Training Requirement: Direct support workers must be trained per the participant’s person-centered service plan.
• On-Call Support: AFC Authorized Agencies must provide 24-hour consultation and support to caregivers.
• Worker Qualifications: Must be at least 18 years of age and capable of providing the services outlined in the care plan.

7. Documentation, Policies and Records

Vermont requires CFC providers to maintain strict documentation standards, which are subject to review during DAIL utilization reviews and audits. At a minimum, agencies must maintain electronic access to critical incident reports, backup plans, and service authorizations.

The individual's Case Manager is responsible for the person-centered planning process, but the companion care provider must track and report information back to the Case Manager regarding the participant's goals and well-being.

• Service Plan: Must maintain a copy of the approved AFC Service Plan Authorization (CFC Form 805D) or Home Care authorization.
• Emergency Plan: A 24-hour emergency back-up plan must be on file and accessible.
• Incident Reporting: Must comply with the DAIL Critical Incident Policy and report incidents within required timeframes.
• Disclosure Policy: Must follow AFC Disclosure of Information Procedures (Section V.15 of the program manual).
• Record Retention: Medicaid records must be retained for a minimum of six years.

8. Billing, Rates and Claims

Companion care services are billed to Vermont Medicaid using specific HCPCS codes and revenue codes outlined in the Choices for Care provider manual. Rates are established by the state and published on the DAIL ASD Medicaid Service Rates page.

Providers submit claims electronically through the Gainwell Technologies MMIS portal. CFC shall not pay for any service already paid to a Shared Living Provider in a separate arrangement, preventing duplicative billing.

• Rate Publication: Current rates are published on the DAIL ASD Medicaid Service Rates document (https://asd.vermont.gov/document/medicaid-service-rates).
• Billing System: Claims are submitted via the Gainwell Technologies provider portal.
• Revenue Codes: AFC Authorized Agencies bill using Revenue Code 086; Case Management uses 070.
• Prior Authorization: Services must be explicitly identified on the participant's Service Plan Authorization before billing.
• Third-Party Liability: Medicaid is the payer of last resort; providers must exhaust other insurance before billing CFC.

9. Approval Sequence and Timeline

The approval process in Vermont is strictly sequential. An agency must first download the fillable Home Care Provider Application from the DAIL ASD website, complete it with all required attachments, and email it to the DAIL Provider Enrollment inbox.

DAIL reviews the application for programmatic compliance. If approved, DAIL issues an authorization letter and instructs the provider to apply through the Gainwell Medicaid portal. The entire process typically takes 60 to 90 days, depending on application completeness.

• Step 1: Download the fillable Home Care Provider Application from the DAIL ASD website.
• Step 2: Submit the completed application and attachments to [email protected].
• Step 3: DAIL ASD conducts a programmatic review and issues an approval letter.
• Step 4: Submit the Medicaid Provider Enrollment application via the Gainwell portal, attaching the DAIL approval.
• Step 5: Gainwell processes the enrollment and issues a Vermont Medicaid Provider ID.

10. Common Denials and Survey Findings

Applications to DAIL ASD are frequently delayed or denied because prospective providers fail to include required attachments or do not adequately demonstrate how they will meet the CFC Universal Provider Qualifications.

During utilization reviews or audits, common findings include failure to maintain updated 24-hour emergency backup plans, lapsed background checks for direct support workers, and billing for services not explicitly authorized on the CFC Form 805D.

• Incomplete Applications: DAIL will return applications that lack required policy attachments or signatures.
• Background Check Lapses: Employing staff before the AHS Background Check Unit clears them.
• Unauthorized Billing: Submitting claims for companion hours that exceed the authorized amount on the Service Plan.
• HCBS Settings Violations: Failing to demonstrate that the service delivery model integrates the participant into the broader community.

11. Key Contacts and Resources

Prospective providers should begin by reviewing the Provider Enrollment Process Summary on the DAIL ASD website. The Adult Services Division is the primary point of contact for all programmatic questions regarding the Choices for Care waiver.

For technical assistance with the Medicaid enrollment portal or claims submission, providers must contact Gainwell Technologies Provider Services.

• DAIL Adult Services Division (ASD): https://asd.vermont.gov/
• DAIL Provider Enrollment Email: [email protected]
• Vermont Medicaid Portal (Gainwell): https://vtmedicaid.com/
• Department of Vermont Health Access (DVHA): https://dvha.vermont.gov/
• Choices for Care Program Manual: Available via the DAIL ASD Document Library.

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