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

Last reviewed: 2026-09-10

The Vermont Department of Disabilities, Aging and Independent Living (DAIL) Adult Services Division (ASD) approves agencies to deliver Personal Assistance Services through the Choices for Care (CFC) 1115 Waiver. Applicants must first submit the CFC Provider Enrollment Application directly to DAIL ASD for programmatic approval before they are permitted to apply for Medicaid billing privileges.

Vermont does not issue a standalone "non-medical home care" license for personal care agencies. Instead, traditional agency-based personal care is delivered either by designated Home Health Agencies regulated by the Division of Licensing and Protection (DLP) or by specialized waiver providers who pass the ASD programmatic review and enroll directly with the Vermont Medicaid fiscal agent.

1. Service Definition and Scope

Under the Choices for Care waiver, Personal Assistance Services provide hands-on assistance with activities of daily living (ADLs) such as bathing, dressing, eating, transferring, and toileting. Services are delivered in the participant's own home to maintain their independence and prevent institutionalization.

The service also encompasses instrumental activities of daily living (IADLs) like light housekeeping and meal preparation, provided these are incidental to the direct personal care being delivered.

2. Regulatory and Oversight Agencies

The Department of Disabilities, Aging and Independent Living (DAIL) oversees the programmatic and quality aspects of the Choices for Care waiver. Within DAIL, the Adult Services Division (ASD) handles waiver provider approvals.

The Division of Licensing and Protection (DLP) handles regulatory oversight for designated Home Health Agencies, while Vermont Medicaid manages the financial and claims infrastructure.

3. Gatekeeping Prerequisites: Who Can Even Apply

Vermont strictly controls the entry of new personal care providers through a bifurcated system. Agencies seeking to operate as comprehensive Home Health Agencies must obtain a Certificate of Need (CON) from the Green Mountain Care Board and subsequent designation from DAIL.

Non-HHA providers seeking to offer only waiver-based personal care must pass the DAIL ASD programmatic approval process. Medicaid enrollment applications are automatically rejected if the applicant has not first secured this DAIL ASD approval letter.

4. Licensure and Certification Requirements

Because Vermont does not have a distinct "personal care agency" license, providers operate either under a Home Health Agency designation or as an unlicensed, DAIL-certified waiver provider.

Designated HHAs must comply with the Home Health Agency Designation and Operation Regulations. Waiver-only providers must adhere to the Choices for Care program manual and provider agreement standards.

5. Medicaid Provider Enrollment

After securing DAIL ASD approval, providers must enroll through the Vermont Medicaid Portal managed by Gainwell Technologies. The enrollment process requires the submission of the DAIL approval letter alongside standard federal disclosures.

Providers must complete the enrollment application specific to atypical or waiver providers, depending on their exact NPI and taxonomy setup.

6. Staffing, Training and Background Checks

Direct care workers providing Personal Assistance Services must meet minimum competency standards outlined in the Choices for Care manual. Agencies are responsible for verifying these competencies before a worker provides unsupervised care.

Comprehensive background checks are mandatory for all patient-facing staff, utilizing Vermont's state registries and national databases.

7. Documentation, Policies and Records

Providers must maintain comprehensive records that align with DAIL ASD standards and Medicaid billing requirements. This includes detailed care plans and daily service logs.

Agency policies must cover incident reporting, participant rights, and emergency preparedness, ensuring compliance with the HCBS Settings Rule.

8. Billing, Rates and Claims

Claims for Personal Assistance Services are submitted to Vermont Medicaid via the Gainwell Technologies MMIS portal. Services are billed in 15-minute increments using specific HCPCS codes.

Rates are established by the Agency of Human Services and published in the Vermont Medicaid fee schedule. Prior authorization from the CFC case manager is required for all billable units.

9. Approval Sequence and Timeline

The pathway to becoming a billable provider requires sequential approvals, starting with the state programmatic division before moving to the fiscal agent.

The entire process can take several months, heavily dependent on the completeness of the initial DAIL ASD application and the current processing times at Gainwell Technologies.

10. Common Denials and Survey Findings

Applications are frequently delayed or denied if providers attempt to bypass the DAIL ASD approval step and apply directly to Medicaid.

During audits or surveys, common citations involve inadequate documentation of service times and failure to complete required background checks prior to a caregiver's first shift.

11. Key Contacts and Resources

Providers should utilize the official state portals and division contacts for the most current forms, manuals, and fee schedules.

The DAIL ASD and Vermont Medicaid websites are the primary hubs for regulatory updates and enrollment instructions.

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