How to start a home care agency in Minnesota (2026 rules)

How to start a home care agency in Minnesota changed in 2026. The licensing steps are the same, but the Minnesota Department of Human Services (DHS), at the direction of the Centers for Medicare & Medicaid Services (CMS), has frozen new Medicaid enrollment for most service lines a new agency would choose. As of September 2026, you cannot enroll a new Community First Services and Supports (CFSS) agency, adult rehabilitative mental health services (ARMHS) provider, individualized home supports provider, adult day center, or Early Intensive Developmental and Behavioral Intervention (EIDBI) agency, and you cannot get a new 245D license.

What remains open is the Minnesota Department of Health (MDH) home care license under Minn. Stat. § 144A.471, which is required to provide home care services in the state regardless of who pays. An MDH-licensed agency can serve private-pay and long-term care insurance clients now, and can enroll with Minnesota Health Care Programs (MHCP) for services that are not on the freeze list.

This guide covers the choice of service line, the MDH license, formation and insurance, MHCP enrollment, background studies, electronic visit verification (EVV), policies, staffing, software, and a timeline. The DHS enrollment freeze page and the MDH licensing page are the sources of truth.

Which service line can you actually open?

The freeze list, effective January 27, 2026, covers adult companion services, adult day services, ARMHS, assertive community treatment, CFSS agencies, EIDBI agencies, individualized home supports, integrated community supports, intensive residential treatment services, night supervision services, nonemergency medical transportation, peer recovery support services, and recuperative care. In July 2026, DHS extended the pause for 12 categories through January 27, 2027. Every exception needs written CMS approval.

The Minnesota Revalidate and enrollment freeze guide tracks the dates. If your plan depends on a frozen line, the options are to buy an existing enrolled agency (a change of ownership is reported to MHCP at least 30 days ahead, and the new owner must pass screening before claims are paid) or to open under an MDH license now and add Medicaid lines when the freeze lifts.

Compliance note: an MDH home care license does not let you bill MHCP for CFSS. Read the PCA to CFSS transition guide before assuming a home care license is a route into personal care billing.

The MDH home care license

Minn. Stat. § 144A.471 says a home care provider "may not open, operate, manage, conduct, maintain, or advertise itself as a home care provider" without a temporary or current license from the commissioner of health. There are two levels.

• Basic home care license. Assistive tasks: dressing, self-feeding, hygiene, standby assistance, medication and treatment reminders, modified diet preparation, and household services provided with at least one of those tasks.
• Comprehensive home care license. Everything in basic, plus services by licensed nurses, therapists, and social workers; delegated nursing tasks; medication management; mobility assistance; treatments and therapies; and complex specialty care.

Under § 144A.472, the application lists the principal and branch offices, owners and managerial officials, background study documentation, proof of workers' compensation coverage, liability documentation where applicable, the license level, and the manager of day-to-day operations. You also verify written policies on maltreatment reporting, background studies, staff training, complaint handling, client evaluation, the home care bill of rights, infection control, medication reminders, and tuberculosis screening.

The initial fee is $2,100 for a basic license and $4,200 for a comprehensive license. Renewal fees are set by the prior year's home care revenue, from $231 to $7,651, and licenses run one year.

Temporary license and survey

§ 144A.473 sets the clock. MDH acknowledges a complete application within 14 calendar days and issues a temporary license, or denies it, within 90 days. The temporary license is effective for up to one year. You must notify MDH within five days of beginning services, and MDH conducts an on-site survey within 90 calendar days after it learns you are serving clients. Substantial compliance converts the temporary license to a full license; otherwise MDH may deny it or extend it for up to 90 days with conditions.

Business formation, insurance, and bonding

Form the entity first, because every application asks for the legal name, federal employer identification number, and owners and controlling individuals exactly as filed with the Minnesota Secretary of State.

MDH requires proof of workers' compensation coverage and liability documentation where applicable. MHCP enrollment for agency provider types requires a certificate of liability insurance naming DHS Provider Eligibility and Compliance as certificate holder, and personal care agency enrollment has required a $50,000 surety bond for first-time enrolling providers, plus fidelity bond coverage for CFSS agencies. Get quotes before you apply.

MHCP enrollment through the MPSE portal

If you will bill Medicaid for any open service, enroll through the Minnesota Provider Screening and Enrollment (MPSE) portal. That is where you submit the enrollment record for each site, list owners and authorized people, upload licenses and insurance, and later manage revalidation.

Expect a CMS application fee per practice location ($750 in 2026) unless you paid it to Medicare or another state, fingerprint-based background studies for every direct or indirect owner with a 5 percent or greater interest, and an unannounced site visit for high-risk provider types. Once enrolled, keep an active MN-ITS mailbox; DHS sends revalidation notices there, and a missed notice leads to disenrollment.

Background studies through NETStudy 2.0

Every person with direct client contact, and every owner, manager, and board member the statute names, needs a background study before starting work. MDH applicants submit studies under Minn. Stat. §§ 144A.476 and 144.057 through the DHS NETStudy 2.0 system, under the agency ID assigned to your license or enrollment. MHCP adds fingerprint-based studies for owners, with a $44 fee per study plus fingerprinting costs. A disqualification without a set-aside means that person cannot provide services, so run studies on your founding team first.

EVV setup with HHAeXchange

Minnesota's Medicaid EVV mandate covers personal care and home health services with in-home visits. Effective January 1, 2026, every provider of those services must complete HHAeXchange enrollment regardless of which EVV system or payer it uses, and must submit data for every visit, including noncompliant ones. At least 50 percent of visits billed after January 1, 2026 had to be EVV compliant, and at least 80 percent from July 1, 2026. Manually entered or missed visits count as noncompliant.

A new agency can use the state-provided HHAeXchange system at no cost or a third-party system that sends data to the HHAeXchange aggregator. Decide before your first Medicaid visit. The Minnesota EVV requirements guide covers thresholds, enrollment, and corrective action.

Policies, staffing, and training

The MDH application requires the policies above to exist before the license is issued, and the survey checks that staff were trained on them. Write them for your actual operation. At minimum you need:

• Client intake, evaluation, and service plan procedures, including the home care bill of rights.
• Staff orientation and training records, with competency verification before unsupervised work.
• Maltreatment reporting, complaint handling, and infection control.
• Medication reminder or medication management procedures matching your license level.
• A HIPAA privacy and security program with a business associate agreement from every vendor that touches client data; see the HIPAA compliance guide.

Hire a manager of day-to-day operations you can name on the application, a registered nurse if you are going comprehensive, and caregivers whose background studies clear before the first shift. For 245D or adult day lines later, the 245D license guide and the adult day services license guide describe the training rules that apply when those pauses end.

Software and documentation from day one

A surveyor and, later, a DHS reviewer will ask for the client record, staff file, schedule, visit verification, and claim for a given date. Pick a system that keeps those in one place before you take a client: documentation with required fields enforced, a caregiver app with GPS clock-in and client signatures, scheduling tied to authorizations, claims with remittance reconciliation, role-based access, a signed BAA, and an audit log. If you plan to add EIDBI when its moratorium ends, check that the platform supports the EIDBI provider requirements for supervision and session notes. Trustora's pricing is a flat monthly fee with unlimited users and clients, which matters when a startup adds staff faster than revenue.

A realistic timeline

The calendar is set mostly by statutory review windows, so plan around them.

Report any change in the application information to MDH within ten working days.

How Trustora helps

Trustora is one platform for the documentation, scheduling, EVV, and billing a new Minnesota agency needs, with onboarding, migration, and training included and typically completed in one to two weeks. Client records enforce required fields for assessments, service plans, and visit notes; the caregiver app on iOS and Android captures GPS clock-in and clock-out and client signatures; and a pre-claim gate stops a claim when the note, authorization, or EVV record behind it is missing.

Because it supports ARMHS, 245D, PCA/CFSS, EIDBI, and adult day services alongside home care, an agency that starts under an MDH license can add Medicaid lines when the freeze ends without changing systems. Access is role-based and field-level, data is encrypted at rest and in transit, and every record carries an append-only audit log with seven-year retention, so the file you show a surveyor in year one is the file you show a DHS reviewer in year five.