The CFSS agency model vs budget model decision is really one question: who is the employer of the support worker? In the agency model, a Community First Services and Supports (CFSS) provider agency employs the worker and bills authorized units. In the budget model, the participant employs the worker, the lead agency authorizes a dollar budget, and a financial management services (FMS) provider does the payroll and paperwork.
Both models come from Minn. Stat. § 256B.85. Both pay for the same covered services, both hold the worker to the same enrollment and training rules, and both are subject to electronic visit verification (EVV). The differences are in control, responsibility, union coverage, and what a claim looks like.
This comparison is for participants and families choosing a model, and for agency staff who need to explain the choice or handle a switch. It reflects the statute and Minnesota Department of Human Services (DHS) guidance as of September 2026. If you are new to the program, start with what CFSS is.
Agency model vs budget model at a glance
| Topic | Agency model | Budget model |
|---|---|---|
| Who employs the worker | The CFSS agency-provider | The participant, or a legal representative or participant's representative on their behalf |
| What the lead agency authorizes | Units of service; one unit is 15 minutes, in a service agreement of up to 12 months | A service budget in dollars, based on the same assessment |
| Recruiting and hiring | The agency, with the participant having "a significant role in the selection and dismissal" of workers | The participant recruits, interviews, and hires |
| Scheduling | The agency, with the participant | The participant |
| Payroll, payroll taxes, workers' compensation | The agency | The FMS provider pays them from the participant's budget; the worker is not the FMS provider's employee |
| Supervision and competency | The agency observes the worker within 30 days, keeps evidence, and reviews performance at least annually (subd. 11b) | The participant evaluates competency within 30 days and when the plan or condition changes (subd. 14) |
| Service evaluation | The agency evaluates the service within 90 days and at least quarterly, in person during the first year (subd. 11a) | The consultation services provider and FMS provider support the participant |
| Consultation services | Available; check the current DHS CFSS manual for when it is required | Required (subd. 13) |
| Financial management services | Used only to bill and pay for approved goods | Required for every participant (subd. 13a) |
| What the participant can purchase | Support worker services, plus goods listed in the plan and paid through an FMS provider | Support worker wages and employer costs, plus supports and goods within the budget |
| Worker training and development | Provided or arranged by the agency, funded on top of the units (subd. 18a) | Purchased by the participant employer, funded on top of the budget (subd. 18a) |
| Worker enrollment, training, background study | Same in both: DHS enrollment after a chapter 245C study, standardized CFSS training, certification test (subd. 16) | Same |
| Union coverage | Not covered by the SEIU contract; wages set by the agency under the 72.5 percent wage-and-benefit floor | Covered by the SEIU collective bargaining agreement and its minimum wage schedule |
| Who bills MHCP | The agency, T1019 in 15-minute units per rendering worker | The FMS provider, T1019 against the participant's authorized funds |
| EVV | Required; the agency is the EVV provider | Required; the FMS provider is the EVV provider |
| Who must use it | Participants restricted under the Minnesota restricted recipient program (subd. 11) | Participants who can carry, or have a representative who can carry, the employer duties in subd. 14 |
| Leaving the model | Revised service delivery plan and new authorization | Same, but a participant who exits mid-year cannot return to the budget model until the next plan year (subd. 13) |
Who employs and supervises the worker
In the agency model the statute says services are provided by workers "who are employed by an agency-provider." The agency must "make a reasonable effort to fulfill the participant's request for the participant's preferred support worker," and the participant takes part in evaluating the service and the workers.
In the budget model, subd. 14 puts the employer duties on the participant or the participant's representative: "the hiring and supervision of the support worker, including but not limited to recruiting, interviewing, training, scheduling, and discharging the support worker." The participant also orients the worker, tracks services and spending, verifies time sheets, reports employment changes to the FMS provider, and evaluates competency within 30 days of the worker starting.
The FMS provider's role is narrower than it looks. Under subd. 13a it files and pays payroll taxes and premiums, runs chapter 245C background studies, bills approved services, monitors and disburses funds, helps obtain insurance coverage, and gives the participant "instruction and technical assistance" on employer requirements. The statute adds that "the support worker shall not be considered the employee of the FMS provider" and that "agency-provider services shall not be provided by the FMS provider." A participant who cannot carry the employer duties can be moved by DHS to the agency model, with a right to appeal.
What the participant can purchase in each model
Both models pay for the covered services in subd. 7, from help with daily living and health-related tasks to goods and environmental modifications, consultation, and worker training. The difference is how goods are bought. A budget-model participant spends the approved budget directly on "supports and goods as defined in subdivision 7," with the FMS provider paying and accounting for them. An agency-model participant may also purchase goods, but must list them in the service delivery plan and detailed budget approved by the lead agency, case manager, or care coordinator, and must use an FMS provider to bill and pay for them. Worker training and development is funded on top of the units or budget in both models; in the agency model it is billed as S5116, and the CFSS billing guide lists the codes.
Worker training, competency, and union coverage
The worker qualification rules do not change with the model. Under subd. 16 a support worker in either model enrolls with DHS after a background study, completes the standardized CFSS training, passes the certification test, and completes employer-directed orientation on the participant's needs. The CFSS support worker requirements guide has the full list.
What changes is who documents competency. An agency must evaluate the worker "through direct observation of the support worker's performance of the job functions in a setting where the participant is using CFSS within 30 days" of starting, keep evidence of education, training, and orientation, review performance at least annually, and maintain a worker training and development plan. DHS transition guidance describes the operating standard as a competency visit within 30 days of hire and every 90 days after that, in person during the first year. A budget-model participant carries a parallel 30-day duty under subd. 14; the 90-day cadence is agency guidance.
Union coverage follows the model. Budget-model workers are individual providers covered by the SEIU collective bargaining agreement with the state, including its tiered minimum wage schedule. Agency-model workers are not. Instead, subd. 11 requires the agency to use "a minimum of 72.5 percent of the revenue generated by the medical assistance payment for CFSS for support worker wages and benefits," to document how it meets that floor, and to pass through all of any rate increase that results from a collective bargaining agreement. The agency also may not require a worker to sign a noncompete covering any participant or another CFSS agency.
Compliance note: the 30-day competency check is a statutory requirement in both models, and in the agency model the record of that observation is compared to the worker's first claim dates. A first observation dated after day 30 puts every earlier unit at risk.
EVV and documentation in both models
CFSS personal care in both models has been an in-scope EVV service since October 1, 2024. The billing provider carries the obligation: the agency in the agency model, the FMS provider in the budget model. As of January 1, 2026 that provider must be enrolled with HHAeXchange regardless of its EVV system, and as of July 1, 2026 at least 80 percent of billed visits must be EVV compliant; DHS has stated the requirements apply to FMS providers as well.
Subd. 15 sets the same time sheet rule for both: each worker documents services daily and submits time sheets at least monthly, and the agency (or the participant and FMS provider) verifies them. Time sheets may be electronic, which in practice means the EVV record.
How a participant switches between models
- The participant tells the lead agency, the consultation services provider, and the current provider that they want to change models.
- The consultation services provider helps revise the person-centered service delivery plan, including the detailed budget for expenditures if moving to the budget model.
- The lead agency approves the plan and issues a new service authorization: units to the agency, or dollars to the FMS provider. If the lead agency cannot update the authorization directly, it sends the CFSS Request Form (DHS-6893I) to DHS.
- The old provider bills only the dates its authorization covers; the new provider starts when its authorization begins.
The one-way rule matters for planning. Under subd. 13(e), a participant who exits the budget model during the service plan year "shall not access the budget model for the remainder of that service plan year." Moving from agency to budget has no equivalent lockout. A participant restricted under the Minnesota restricted recipient program must use the agency model.
Pros and cons for participants
Agency model. The agency recruits and replaces workers, covers absences, runs payroll, and carries the employer liability. The participant still chooses and can dismiss workers, but the agency sets wages and schedules, and goods must go through the plan and an FMS provider.
Budget model. The participant sets the wage (at or above the SEIU minimum), picks the schedule, and can direct the budget to goods and supports. The participant, or a representative, must recruit, train, supervise, document competency, and cover absences. Consultation and FMS services are required, and exiting mid-year means waiting until the next plan year to return.
Pros and cons for agencies
Serving the agency model. Units are predictable, the agency controls scheduling and quality, and the worker training and development budget funds supervision time. In exchange the agency carries the 72.5 percent wage floor, the cost report when selected, the competency visits, quarterly evaluations, and the full EVV and pre-payment review burden.
Participants who choose the budget model. An agency does not serve them directly; the FMS provider does, and enrolling as an FMS provider is a separate enrollment with its own duties under subd. 13a and its own EVV compliance rate. Understanding both models lets an agency explain the choice honestly during the PCA to CFSS transition and keep a participant who later switches back.
How Trustora helps
Trustora is built for the agency model. Each participant record stores the service authorization with its unit total and period, the service delivery plan and lead agency addendum, and the signed participant agreement, so a model switch shows up as a new authorization period rather than a manual note. Scheduling is bounded by the authorization, and the pre-claim gate blocks a T1019 line that falls outside it.
Worker files hold the CFSS training certificate, background study result, MHCP enrollment and affiliation dates, and the 30-day and 90-day competency visits with alerts before a visit is due, and payroll exports of verified hours support the 72.5 percent wage-and-benefit documentation. The caregiver app on iOS and Android captures GPS clock-in and clock-out and the participant's signature and sends every visit to HHAeXchange. See the features page for the scheduling, EVV, and claims workflow.