Vermont - Transitional 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) authorizes Community Transition Services (the state's term for Transitional Assistance) under the Choices for Care (CFC) and Traumatic Brain Injury (TBI) 1115 waiver programs. Providers must navigate a strict pre-approval sequence, as the state does not issue a distinct facility or agency license for this service category.

Independent organizations cannot simply enroll as standalone transition providers; any non-designated entity seeking to provide these services must either secure programmatic pre-approval directly from DAIL ASD using the CFC/TBI Provider Enrollment Application or operate as a formal subcontractor under one of Vermont's existing Designated Agencies (DAs) or Specialized Services Agencies (SSAs).

1. Service Definition and Scope

Vermont defines this service as Community Transition Services, which covers one-time, non-recurring setup expenses for individuals transitioning from an institutional setting, such as a nursing facility, into a community-based independent living arrangement. The service is designed to remove financial barriers to community integration.

Allowable expenses are strictly limited to essential items and services required to establish a basic household. The service does not cover ongoing living expenses or luxury items.

• Program Name: Community Transition Services under the Choices for Care (CFC) and Traumatic Brain Injury (TBI) programs
• Covered Expenses: Security deposits, utility setup fees, essential household furnishings, window coverings, and moving expenses
• Excluded Costs: Monthly rental or mortgage payments, food, regular utility charges, and recreational items like televisions
• Funding Cap: Authorized on a per-transition basis as strictly defined in the participant's approved care plan
• Target Population: Medicaid beneficiaries residing in nursing facilities or rehabilitation centers who are transitioning to an independent community home

2. Regulatory and Oversight Agencies

Programmatic oversight and waiver management are handled by the Department of Disabilities, Aging and Independent Living (DAIL). The Medicaid financial and enrollment infrastructure is managed by the Department of Vermont Health Access (DVHA).

Providers must interact with both departments, securing programmatic approval from DAIL before interacting with DVHA's fiscal agent for claims and enrollment.

• Program Operator: DAIL Adult Services Division (ASD) (https://asd.vermont.gov)
• Medicaid Authority: Department of Vermont Health Access (DVHA) (https://dvha.vermont.gov)
• Fiscal Agent and Portal: Gainwell Technologies Vermont Medicaid Portal (https://vtmedicaid.com)
• Designating Authority: DAIL Developmental Disabilities Services Division (DDSD) (https://ddsd.vermont.gov)

3. Gatekeeping Prerequisites: Who Can Even Apply

Vermont operates a highly controlled HCBS network that relies heavily on a statutory designation model. New entrants face significant structural preconditions before a Medicaid enrollment application will be accepted.

Providers must either achieve designation, secure a subcontract, or pass a specific DAIL pre-approval review that functions as a need-review gate.

• DAIL Pre-Approval: Mandatory prerequisite; no Medicaid enrollment application is accepted by Gainwell without a formal approval letter from DAIL ASD
• Designated Agency Subcontracting: Under Code Vt. R. 13-174-007-X Section 10.6, non-designated entities often must secure a subcontract with an existing Designated Agency (DA) or Specialized Services Agency (SSA)
• Territorial Exclusivity: Vermont home health agencies operate under a designated, exclusive territory model, preventing new agencies from easily entering to provide overlapping transition or case management services
• Need Review: DAIL ASD reviews the CFC/TBI Provider Enrollment Application to determine if the applicant meets current network adequacy and geographic needs

4. Licensure and Certification Requirements

Vermont does not issue a distinct state license for Transitional Assistance or Community Transition Services. Instead, providers are certified through the DAIL ASD provider enrollment process.

Applicants must demonstrate compliance with baseline state standards rather than passing a traditional facility licensure survey.

• Licensure Exemption: No specific state license exists for transition coordination; legal authority to operate is granted via DAIL certification
• Universal Provider Standards: Applicants must attest to and demonstrate compliance with DAIL's baseline HCBS Universal Provider Standards
• Agency Certification: DAs and SSAs must maintain active designation status under the Vermont Administrative Rules on Agency Designation
• Application Form: CFC & TBI Provider Enrollment Process application, which must be submitted to [email protected]

5. Medicaid Provider Enrollment

Once DAIL ASD issues a programmatic approval letter, the provider must enroll as a billing entity with Vermont Medicaid. This process is managed by DVHA's fiscal agent, Gainwell Technologies.

The enrollment is processed entirely online through the Provider Management Module (PMM), and the DAIL approval must be uploaded as an attachment.

• System: Provider Management Module (PMM) accessed via vtmedicaid.com
• Prerequisite Document: The official DAIL ASD approval letter must be uploaded with the Gainwell application
• Form Type: State institutional or atypical provider enrollment packet, depending on the provider's NPI status and exact service taxonomy
• Application Fee: Standard Medicaid application fee applies unless waived due to prior payment to Medicare or another state's Medicaid program
• Processing Timeline: Gainwell processing typically requires 30 to 60 days after the DAIL approval is submitted

6. Staffing, Training and Background Checks

Staff members coordinating transitions or purchasing goods on behalf of participants must pass comprehensive state background checks. Vermont strictly enforces abuse registry clearances.

Agencies must maintain personnel files proving that all direct-contact staff have completed mandatory state training modules.

• Background Check: Adult Protective Services (APS) and Child Abuse Registry checks are mandatory for all direct-contact staff
• Criminal History: Vermont Crime Information Center (VCIC) fingerprint-based background check required prior to client contact
• Mandatory Training: Staff must complete Vermont Adult Protective Services (APS) mandatory reporter training
• Qualifications: Transition coordinators typically must hold a bachelor's degree in human services or possess equivalent documented experience in HCBS case management

7. Documentation, Policies and Records

Because Community Transition Services involve purchasing physical goods and paying third-party vendors (like landlords or utility companies), financial documentation requirements are rigorous.

Providers must maintain a clear paper trail linking every dollar spent to the specific participant's authorized care plan.

• Financial Records: Original receipts and paid invoices must be retained for all security deposits, furnishings, and moving costs
• Care Plan Alignment: Documentation must explicitly link every purchased item to the transition plan approved by the CFC or TBI case manager
• Policy Requirement: Agencies must maintain written policies on critical incident reporting, grievance procedures, and participant rights
• Record Retention: Vermont requires all Medicaid and waiver service records to be retained for a minimum of 7 years

8. Billing, Rates and Claims

Transition services are billed through the Gainwell MMIS. Unlike hourly personal care, these services are typically billed as pass-through costs for actual expenses incurred.

Providers cannot bill for any item or service that was not explicitly prior-authorized by the state case manager.

• Billing System: Gainwell Technologies Provider Electronic Solution (PES) or direct 837P/837I EDI submission
• Procedure Code: T2038 (Community Transition, waiver; per service) is the standard code, with specific modifiers applied for CFC versus TBI funding
• Prior Authorization: 100 percent of transition expenses require prior authorization from the DAIL ASD case manager before the purchase is made
• Reimbursement Model: Pass-through reimbursement for actual receipted costs up to the authorized cap, occasionally accompanied by a distinct administrative coordination fee

9. Approval Sequence and Timeline

The approval process in Vermont is strictly sequential. Providers cannot initiate Medicaid enrollment until the programmatic division has fully vetted and approved the agency.

Attempting to submit forms out of order will result in immediate rejection by the fiscal agent.

• Step 1: Submit the CFC/TBI Provider Enrollment Application directly to DAIL ASD (review takes 30-60 days)
• Step 2: Receive the official DAIL ASD programmatic approval letter
• Step 3: Submit the Medicaid enrollment application via the Gainwell PMM portal, attaching the DAIL letter (30-60 days)
• Step 4: Receive the Welcome Letter and Provider ID from DVHA
• Step 5: Receive specific participant prior authorizations from case managers and begin purchasing transition goods

10. Common Denials and Survey Findings

Most enrollment denials occur at the Gainwell stage when providers fail to include the required DAIL pre-approval. Post-enrollment audit findings heavily focus on financial documentation.

Auditors frequently recoup funds if a provider cannot produce original store receipts for household goods.

• Premature Enrollment: Gainwell denying applications because the DAIL ASD approval letter is missing or expired
• Unapproved Purchases: Billing for transition items (such as premium furniture or electronics) that were not explicitly authorized in the care plan
• Missing Receipts: Recoupment of funds during state audits due to missing original store receipts or vendor invoices for household goods
• Subcontracting Failures: Non-designated agencies failing to secure, renew, or maintain their required subcontract with a DA or SSA

11. Key Contacts and Resources

Providers should direct programmatic and waiver rule questions to DAIL ASD. Technical billing and portal enrollment questions must go to Gainwell Technologies.

The state's official portals are the only authoritative sources for current forms and manuals.

• DAIL Adult Services Division: https://asd.vermont.gov
• DAIL Provider Enrollment Email: [email protected]
• Vermont Medicaid Portal (Gainwell): https://vtmedicaid.com
• DVHA Provider Enrollment Unit: https://dvha.vermont.gov/providers/provider-enrollment

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