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

Last reviewed: 2026-08-16

In Vermont, Adult Companion Services are primarily funded through the Choices for Care (CFC) 1115 Long-Term Care Medicaid Waiver and the Developmental Disabilities Services Division (DDSD) Home and Community Based Services (HCBS) waiver. The service provides non-medical supervision, socialization, and assistance with daily living tasks to help older adults and individuals with disabilities remain safely in their homes and communities.

The single biggest structural barrier to entry in Vermont is that the state does not issue a standalone license for "Companion Agencies." Furthermore, Vermont operates a strict territorial designation model for Home Health Agencies (HHAs), meaning new entrants cannot easily become Medicare-certified HHAs. Instead, to provide companion services independently, an agency must apply for and secure pre-approval as a certified "Home Care Provider" through the Department of Disabilities, Aging and Independent Living (DAIL) Adult Services Division (ASD) before they are permitted to submit a Medicaid enrollment application.

1. Service Definition and Scope

Vermont defines Companion Services under the Choices for Care High/Highest Manual (Section IV.5) as non-medical care, supervision, and socialization provided to a functionally impaired adult. Companions may assist or supervise the individual with tasks such as meal preparation, laundry, and shopping, but these activities must be incidental to the primary goal of supervision and socialization.

Providers must strictly adhere to the scope of practice limitations. Companion services do not include hands-on personal care (such as bathing or dressing) or any medical or nursing services. If a participant requires hands-on care, the provider must be authorized for Personal Care services rather than solely Companion Services.

2. Regulatory and Oversight Agencies

The Vermont Agency of Human Services (AHS) serves as the umbrella organization for all health and human services in the state. Within AHS, the Department of Disabilities, Aging and Independent Living (DAIL) is responsible for managing HCBS waivers, setting provider standards, and certifying non-medical home care providers.

The Department of Vermont Health Access (DVHA) acts as the state Medicaid authority, managing the Medicaid Management Information System (MMIS) and final provider enrollment. The Division of Licensing and Protection (DLP), a branch of DAIL, handles survey, certification, and adult protective services investigations.

3. Gatekeeping Prerequisites: Who Can Even Apply

Vermont utilizes a highly structured gatekeeping system that blocks standard open-market Medicaid enrollment. For developmental disability services, Vermont uses a closed network of 10 Designated Agencies (DAs) and 5 Specialized Service Agencies (SSAs); independent providers must typically subcontract under these entities rather than enrolling directly. For home health services, Vermont enforces a territorial exclusivity model, meaning new agencies cannot simply open and compete as Home Health Agencies.

To bypass the HHA territorial monopoly and provide companion services under the Choices for Care waiver, an applicant must successfully complete the DAIL ASD Home Care Provider Certification process. The state will reject any Medicaid enrollment application in the Provider Management Module (PMM) that does not include a formal approval letter from DAIL ASD.

4. Licensure and Certification Requirements

Because Vermont does not issue a specific "Companion Agency" license, providers must meet the Home Care Provider Certification Requirements (updated October 2024). This certification ensures the agency has the administrative capacity, policies, and financial stability to serve vulnerable adults.

Applicants must complete the fillable "Home Care Provider Application" (April 2025 version) and submit it directly to the Adult Services Division. The application requires comprehensive attachments, including organizational charts, grievance policies, and proof of liability insurance.

5. Medicaid Provider Enrollment

Once DAIL ASD issues an approval letter, the agency is instructed to enroll with the state's Medicaid Fiscal Agent, Gainwell Technologies. This is done entirely online through the Provider Management Module (PMM) accessed via the Vermont Medicaid Portal.

Providers must enroll under the specific HCBS waiver provider type authorized by DAIL. Only one service location and one provider type can be enrolled per application, meaning agencies with multiple branches must submit separate enrollments.

6. Staffing, Training and Background Checks

All companion staff must meet the requirements outlined in the DAIL Background Check Policy (Effective July 7, 2017). Agencies are strictly prohibited from allowing any employee to provide direct care until all registry and criminal history checks have cleared.

Staff must be at least 18 years old and possess the ability to communicate effectively with the participant and emergency personnel. Training must include mandated reporting of abuse, neglect, and exploitation, as well as the specific needs outlined in the participant's person-centered plan.

7. Documentation, Policies and Records

Vermont requires Home Care Providers to maintain rigorous documentation to comply with both state waiver regulations and federal CMS Home and Community Based Settings (HCBS) Rules. Agencies must utilize the WellSky Database for tracking participant care plans and service authorizations.

Providers must have written policies for critical incident reporting, grievance procedures, and non-discrimination. Service delivery must be documented with exact start and stop times, detailing the specific socialization or supervision tasks performed during the shift.

8. Billing, Rates and Claims

Companion services are billed through the Medicaid Management Information System (MMIS) via the Vermont Medicaid Portal. Services must be prior-authorized by DAIL and linked to the member's individualized budget before any claims will be paid.

Rates for Choices for Care services are established by DVHA and DAIL and are published in the state's fee schedules. Providers submit professional claims using standard HCPCS codes, and Gainwell Technologies processes clean claims on a weekly payment cycle.

9. Approval Sequence and Timeline

Becoming a companion provider in Vermont is a sequential, two-step process. An agency cannot begin the Medicaid enrollment phase until the DAIL ASD certification phase is entirely complete and an approval letter is in hand.

The entire process typically takes 2 to 4 months. DAIL ASD reviews the Home Care Provider Application, which includes a review of policies and background check procedures. Once approved, the PMM Medicaid enrollment takes an additional 30 to 45 days.

10. Common Denials and Survey Findings

The Division of Licensing and Protection (DLP) Survey and Certification branch conducts audits of Home Care Providers. Initial applications to DAIL are most frequently denied or delayed due to missing policy attachments or failure to demonstrate compliance with the 2017 Background Check Policy.

During post-enrollment surveys, common citations include billing for unapproved hands-on personal care under the companion billing code, and failing to maintain proof of mandated reporter training in personnel files.

11. Key Contacts and Resources

Prospective providers should rely on the official Vermont Agency of Human Services websites for the most current manuals, forms, and fee schedules. The Adult Services Division is the primary point of contact for initial certification questions.

For technical issues regarding the Provider Management Module or claims submission, providers must contact Gainwell Technologies, the state's Medicaid fiscal agent.

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