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

Last reviewed: 2026-09-10

Virginia funds Companion services for adults 18 and older exclusively through the Department of Medical Assistance Services (DMAS) Developmental Disabilities (DD) waivers: Community Living, Family and Individual Supports, and Building Independence.

Approval to bill this service requires an existing base license. The Department of Behavioral Health and Developmental Services (DBHDS) does not issue a standalone companion care license; applicants must first secure and maintain a DBHDS license as a residential, supportive in-home, day support, or respite service provider before adding Companion services to their Medicaid Enterprise System (MES) enrollment.

1. Service Definition and Scope

Under 12VAC30-122-340, Virginia defines Companion service as nonmedical care, socialization, or general support provided to adults.

The service is designed to assist individuals in maintaining safety and participating in community activities, but it cannot be billed concurrently with other similar waiver services.

• Target Population: Adults 18 years of age or older receiving DD waiver services.
• Covered Activities: Nonmedical care, socialization, and general support in the community or home.
• Exclusions: Cannot be provided by adult foster care providers for an individual residing in that foster care home.
• Family Restrictions: For individuals in group homes, sponsored residential, or supported living, companion service cannot be provided by an immediate family member.

2. Regulatory and Oversight Agencies

Two primary state agencies govern the approval and oversight of Companion services in Virginia.

DBHDS handles the physical and programmatic licensing of the base agency, while DMAS manages the financial enrollment and claims processing.

• Licensing Authority: Virginia Department of Behavioral Health and Developmental Services (DBHDS) (https://dbhds.virginia.gov/)
• Medicaid Authority: Virginia Department of Medical Assistance Services (DMAS) (https://www.dmas.virginia.gov/)
• Enrollment Portal: Medicaid Enterprise System (MES) Provider Resources (https://vamedicaid.dmas.virginia.gov/provider)
• Federal Oversight: Centers for Medicare and Medicaid Services (CMS) (https://www.cms.gov/)

3. Gatekeeping Prerequisites: Who Can Even Apply

Virginia does not allow entities to apply solely to be a Companion service provider.

An agency must first clear the structural hurdle of obtaining a broader behavioral health or developmental disability license.

• Base Licensure Mandate: Must hold an active DBHDS license as a residential service provider, supportive in-home residential service provider, day support service provider, or respite service provider (12VAC30-122-340).
• Waiver Allocation: Individuals served must have an assigned DD waiver slot (CL, FIS, or BI) to authorize the service.
• Age Restriction: The agency cannot bill this specific service code for individuals under 18 years of age.
• NPI Requirement: Must obtain a National Provider Identifier (NPI) from NPPES prior to initiating the DMAS enrollment application.

4. Licensure and Certification Requirements

Because Companion services piggyback on a base license, providers must meet the DBHDS licensing standards for their primary service type.

This requires submitting comprehensive policies, procedures, and service descriptions through the DBHDS CONNECT portal.

• Service Description: Must develop a detailed service description per 12VAC35-105-580 outlining goals, care, and admission criteria.
• Initial Application: Submitted via the DBHDS Office of Licensing CONNECT portal for the base service.
• Policy Review: Requires submission of human rights policies, risk management, and emergency preparedness plans.
• Conditional License: DBHDS typically issues a 6-month conditional license to new providers before granting a full annual license.

5. Medicaid Provider Enrollment

Once licensed by DBHDS, providers must enroll with DMAS to bill for waiver services.

DD waiver services are carved out of managed care, meaning providers enroll and bill directly through the state's fee-for-service system.

• System: Provider Registration and Servicing System (PRSS) within the Virginia MES.
• Application Fee: Must pay the CMS-determined institutional application fee unless waived or previously paid to Medicare/another state.
• Screening Risk Level: Subject to ACA provider screening requirements, which may include site visits based on categorical risk.
• Revalidation: Required at least every 5 years via the MES web portal.

6. Staffing, Training and Background Checks

Virginia enforces strict background screening and training requirements for all staff interacting with DD waiver participants.

Agencies must maintain continuous verification of staff eligibility.

• Federal Exclusion Checks: Monthly screening of all employees and contractors against the HHS-OIG LEIE website.
• State Background Checks: Virginia State Police criminal history and DSS Child Protective Services registry checks required.
• Supervisor Qualifications: Must possess at least one year of documented experience working directly with individuals with developmental disabilities and hold a relevant degree or license.
• Direct Support Professional (DSP) Training: Staff must complete DBHDS-approved DSP orientation and DD waiver-specific training modules.

7. Documentation, Policies and Records

Providers must maintain detailed records to justify fee-for-service billing to DMAS.

Auditors look for direct alignment between the authorized support plan and the daily progress notes.

• Individual Support Plan (ISP): Services must be delivered exactly according to the DBHDS-approved ISP.
• Progress Notes: Contemporaneous documentation of socialization and support activities provided during the shift.
• Exclusion Reporting: Must immediately report any discovered OIG exclusions to DMAS in writing.
• Service Ratios: Documentation must prove the provider did not bill for more than one individual at the same time.

8. Billing, Rates and Claims

Companion services under the DD waivers are billed directly to DMAS.

Providers do not bill the CCC Plus Managed Care Organizations for these specific waiver services.

• Methodology: Fee-for-service (FFS) directly to DMAS; carved out of MCO contracts.
• Billing System: Claims submitted via the MES Provider Portal using the assigned 10-digit NPI.
• Concurrent Billing: Providers shall not bill for more than one individual at the same time (12VAC30-122-340).
• Rate Setting: Rates are published in the DMAS DD Waiver Fee Schedule available on the MES portal.

9. Approval Sequence and Timeline

The timeline is dictated by the DBHDS base license acquisition.

Providers cannot expedite the Medicaid enrollment until the DBHDS license is physically issued.

• Step 1: Entity formation, policy drafting, and NPI acquisition.
• Step 2: DBHDS base license application (Supportive In-Home, Respite, etc.) via CONNECT (typically 3-6 months).
• Step 3: DMAS MES Provider Enrollment application and fee payment (typically 30-60 days).
• Step 4: Receipt of service authorization from the individual's support coordinator prior to the first billable shift.

10. Common Denials and Survey Findings

State surveyors frequently cite providers for administrative oversights rather than direct care failures.

Failing to maintain the base license immediately invalidates the Companion service enrollment.

• Missing Base License: Applying for Companion without the prerequisite DBHDS residential, in-home, day, or respite license.
• OIG Screening Failures: Failure to document monthly LEIE checks for all staff.
• Documentation Gaps: Billing for hours not supported by contemporaneous progress notes or exceeding authorized ISP hours.
• Family Caregiver Violations: Billing for Companion services provided by an immediate family member in a group home or sponsored residential setting.

11. Key Contacts and Resources

Providers must rely on official state portals for current regulations and fee schedules.

Do not use third-party summaries for billing codes or compliance standards.

• DBHDS Office of Licensing: https://dbhds.virginia.gov/licensing-information-for-providers
• Virginia Medicaid Enterprise System (MES): https://vamedicaid.dmas.virginia.gov/
• HHS-OIG LEIE Database: https://oig.hhs.gov/exclusions/
• Virginia Administrative Code (Companion Service): https://law.lis.virginia.gov/admincode/title12/agency30/chapter122/section340

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