Adult day services billing in Minnesota: S5102, T2003, attendance records

Adult day services billing in Minnesota rests on three codes and one record. The codes are S5102 for a full day of six or more hours, S5100 for 15-minute units, and T2003 with modifier UC for waiver transportation to and from the site. The record is the daily attendance log with pickup and drop-off times, which the Department of Human Services (DHS) names as the documentation a waiver provider must keep.

Adult day services are paid through home and community-based waivers: the Elderly Waiver (EW) and Alternative Care (AC) for older adults, and the CADI, DD, BI, and CAC disability waivers. Each participant's service is authorized by a lead agency in a service agreement, and the claim goes to Minnesota Health Care Programs (MHCP) through MN-ITS or to the participant's managed care organization (MCO). Rates come from the Disability Waiver Rate System (DWRS) or the Elderly Waiver rate tables; this guide does not state them.

As of September 2026, adult day services is also one of 14 high-risk services subject to DHS pre-payment claim review, which means the attendance record can be requested before a claim is paid. Licensing rules are in the adult day services license guide; the service itself is explained in What are adult day services in Minnesota?, and the plan behind every claim is covered in the plan of care guide.

The adult day services codes

DHS publishes the Long-Term Services and Supports Service Rate Limits chart, form DHS-3945, which lists the procedure codes, units, and eligible programs for each waiver service. The adult day services lines as of the current chart are:

The 15-minute code follows the standard MHCP unit rules in the DHS-3945 billing table. The daily code does not accumulate: a day of five and a half hours is billed in S5100 units, not rounded up to S5102. Family adult day services under Minn. Stat. § 245A.143 use the adult day services codes for the program the participant is enrolled in; confirm the current line on the chart before the first claim.

Waiver transportation under T2003 UC

Transportation between the participant's home and the adult day site is a separate waiver service, not part of the day rate. DHS's waiver billing guidance sets the mechanics:

• Bill T2003 UC per one-way trip. List each date of service on its own claim line and show 1 unit for a one-way trip or 2 units for a round trip.
• The lead agency must authorize the transportation separately in the service agreement. The day service authorization does not cover it.
• T2003 UC is a market-rate service, so the rate is negotiated with the lead agency rather than set by the DWRS framework.
• Waiver transportation cannot be billed for the same time span as another waiver service.
• Transportation during the program day, such as a field trip or an outing, is in-service transportation. Its cost is included in the day service rate and it is not billed as T2003 UC.

For Minn. R. 9555 centers, the transportation rule part also caps one-way travel time at 90 minutes, so the vehicle log needs pickup and drop-off times as well as the trip count.

Rate frameworks: DWRS and the Elderly Waiver tables

Adult day services rates depend on the participant's program. For CADI, DD, BI, and CAC participants, DWRS builds the rate from framework component values that DHS updates by rule and legislative action; the most recent component value update took effect January 1, 2026, subject to federal approval. For EW and AC participants, the rate comes from the Elderly Waiver rate tables published by DHS. Transportation under T2003 UC is market rate under either program.

None of those rates should be hard-coded into a billing system. Look them up on the current DHS-3945 chart and the DWRS or EW rate documents each time they change, and keep the effective dates with the claim so a later review can reconstruct what rate applied on a given day.

Service agreements and units

A waiver claim is payable only if the service is authorized and defined under the federally approved waiver plan and the lead agency has authorized it for that participant. Before billing, the provider needs:

1. A service agreement from the county, Tribe, or MCO that names the service (S5102 or S5100, plus T2003 UC if applicable), the number of days or units, and the start and end dates.
2. Verified waiver eligibility for each month billed. MHCP eligibility can be checked in MN-ITS.
3. Services delivered on the days and times listed on the operating license, since DHS ties reimbursement to the licensed schedule.
4. Units on the claim that do not exceed the authorization. An authorization-exceeded adjustment on the remittance (CO 273 is the code providers saw on CFSS claims in late 2025) means the line will be denied or partially paid even if the day was delivered.

The service agreement usually runs for a fixed period. Track end dates so a renewal request goes to the case manager before the last authorized day, not after the first denial.

Attendance records are the billing evidence

DHS's waiver and AC billing guidance is specific about what an adult day provider must keep. The provider must maintain documentation of a needs assessment and a current plan of care for each person, under Minn. Stat. § 245A.143, subd. 4 to 7 for family adult day services or Minn. R. 9555.9700 for centers. The provider must keep attendance records that show the date of attendance with the day, month, and year and the pickup and drop-off time in hours and minutes, and attendance must be noted daily. Staff who provide services must have reviewed the federal statement that it is a crime to provide materially false information on service billings, and the provider must document that review.

A usable attendance record therefore has, for each participant and each day:

Sign-in sheets with a checkmark and no times will not support a daily code. Participant or caregiver signatures are not required by the guidance quoted above, but many lead agencies expect them, and a signature captured at arrival and departure is the simplest way to show the times are real.

Audit tip: run a monthly reconciliation of three things: the service agreement units, the attendance record, and the claims submitted. Any day that appears in one but not the other two is either a missed claim or a claim without evidence.

Why adult day is attendance-based, not EVV

Electronic visit verification (EVV) applies to Medicaid personal care and home health services with in-home visits: PCA and CFSS, home health aide, skilled nursing visits, therapies, and some 245D services such as individualized home supports. DHS's 2026 thresholds, at least 50% of visits EVV-compliant from January 1, 2026 and at least 80% from July 1, 2026, apply to those services. Adult day services are delivered at a licensed site to a group of participants, so they are attendance-based and are not EVV services.

That is a relief for adult day providers, but it puts the whole evidentiary weight on the attendance record. Agencies that also run PCA or CFSS lines should read the Minnesota EVV requirements guide for those services and keep the two record types separate.

Common adult day services denial reasons

1. No current service agreement, or the claim date falls outside the authorized period.
2. Units exceed the authorization, including T2003 UC trips billed on days no day service was authorized.
3. S5102 billed for a day under six hours. The attendance record shows five hours; the claim shows a full day.
4. Date ranges on the claim. Waiver transportation and daily codes need one line per date.
5. Transportation overlapping another waiver service in the same time span, or in-service transportation billed as T2003 UC.
6. Eligibility lapsed for the month, often at a waiver reassessment or an MCO enrollment change.
7. Attendance record missing or inconsistent when the claim is pulled for pre-payment review.
8. Wrong payer. Fee-for-service claims go to MHCP through MN-ITS; MCO participants' claims go to the plan, and MCO appeals generally must be filed within 60 days of the remittance date.

The MHCP claim denials guide covers how to read remittance codes and correct and resubmit.

Records to keep for an audit

Adult day care was designated a high-risk provider type in January 2026, enrolled centers went through Minnesota Revalidate 2026, and adult day services claims can be held for pre-payment review. A reviewer will ask for, per sampled claim: the service agreement, the eligibility check, the attendance record for that date with times, the plan of care in effect and its last quarterly review, the transportation log, the staff schedule showing ratio compliance that day, and the license showing the operating days and hours. The DHS audit preparation checklist explains how to sample your own claims before a reviewer does.

How Trustora helps

Trustora's adult day module records arrival and departure times at the door, with participant or caregiver signature capture, and turns each day into the right code automatically: S5102 when the day reaches six hours, S5100 units when it does not, and T2003 UC lines per date with one or two units based on the trips logged. The pre-claim gate checks every line against the service agreement's units and dates and against waiver eligibility before the 837P goes out.

Remittance reconciliation posts payments and denials back to the attendance day, and the monthly reconciliation view shows authorized units, attended days, and billed days side by side. When a pre-payment review or audit request arrives, the one-click DHS audit binder assembles attendance, plan of care, transportation, and staffing records for any participant and date range. See the platform overview for the adult day workflow.