What is a person-centered service plan in HCBS?

A person-centered service plan (PCSP) is a federally required document under 42 CFR 441.301 that captures a waiver participant's goals, preferences, backup plans, and authorized services; it must be updated at every reauthorization cycle.

How often must a Medicaid waiver be reauthorized?

Most 1915(c) waivers require annual reauthorization, but some states require it every six months; 1915(i) and 1915(k) waivers and MLTSS contracts also typically run on annual cycles, with the exact window set in each state's approved waiver plan.

Can a case manager authorize home care hours under a Medicaid waiver?

Yes. Under 1915(c), 1915(i), and 1915(k) waivers, the case manager or care coordinator issues the service authorization that determines how many hours of each service type the participant can receive per plan period.

What are the qualifications for a Medicaid waiver?

To qualify for an HCBS waiver, an individual must be Medicaid-eligible, meet the state's functional Level of Care criteria (equivalent to nursing facility level of care for most 1915(c) waivers), and live in a qualifying home or community-based setting.

Is case management covered by Medicaid?

Yes. Case management for HCBS waiver participants is a reimbursable Medicaid service under most state waiver plans, typically billed by the coordinating agency or MCO at a per-member-per-month or per-unit rate.

How long does a Medicaid waiver take to get approved?

Initial Medicaid waiver approval, from eligibility application through first service delivery, typically takes 30 to 90 days depending on state processing times, waiver slot availability, and how quickly the Level of Care assessment and PCSP can be completed.

What is the difference between a waiver case manager and a regular case manager?

A waiver case manager specifically manages participants enrolled in a Medicaid HCBS waiver program, which requires specialized knowledge of LOC determinations, service authorization limits, PCSP federal requirements, and EVV compliance obligations.

HCBS Guide8 min read

HCBS Case Manager Guide to Service Authorization, Care Plans, and Reauthorization

A nationally-scoped workflow for waiver case managers: authorize hours, oversee the PCSP, verify EVV, and run reauthorization on time.

Published May 26, 2026 · By Cal Nesvig, Founding Partner, AveeCare

A woman with a stethoscope around her neck sitting across from another woman and speaking with her in a clinical setting

Key Takeaways

Authorize hours by waiver typeDraft and update the PCSPVerify EVV compliance monthlyReauthorize every 6 to 12 monthsDocument every QA monitoring visit

4.9M+HCBS waiver participants nationwide

50States operating 1915(c) waivers

AnnuallyTypical 1915(c) reauthorization cycle

Reauthorization Readiness Scorecard

Check each item before submitting a reauthorization packet.

What Is HCBS Service Authorization?

HCBS service authorization is the case manager's formal approval of a waiver participant's service types, weekly hours, and authorized units for a plan period.

Federal floor vs. state rules

CMS sets the minimum authorization framework; each state's approved waiver plan adds state-specific requirements for LOC tools, documentation formats, and submission timelines.

Waiver Authority	Typical Population	Who Authorizes	Service Plan Required
1915(c)	Elderly and disabled adults	State CM or support coordinator	Yes, PCSP required
1915(i)	Individuals meeting targeted criteria	State or MCO care coordinator	Yes, PCSP required
1915(k) Community First Choice	Medicaid-eligible with ADL needs	State CM or self-directed	Yes, PCSP required
MLTSS	Managed care enrollees	MCO care manager	Yes, MCO care plan

Service types

Which covered services the participant is approved for, such as personal care, homemaker, respite, or companion services.

Weekly hours and units

The number of authorized hours or billable units per service type, tied directly to the Level of Care findings.

Plan period dates

The start and end dates of the authorization window, which set the reauthorization deadline for the participant.

Under MLTSS arrangements, the MCO's care coordinator plays the authorization role, but federal HCBS settings requirements under 42 CFR 441.301 still apply to every service delivered.

Sources: CMS HCBS · CMS 1915(c) · HCBS waiver types and enrollment

What Does an HCBS Case Manager Do Step by Step?

An HCBS case manager follows a seven-phase cycle from eligibility screening through reauthorization, with EVV verification and billing reconciliation checkpoints in between.

A woman in a professional setting seated in front of an open laptop computer, reviewing information on screen

This workflow applies across 1915(c), 1915(i), 1915(k), and MLTSS arrangements. State-specific timing and portal requirements vary, but the seven phases are consistent at the federal level.

Receive referral and screen eligibility

Confirm Medicaid enrollment, verify that a waiver slot is available, and review the referral against the state's Level of Care (LOC) eligibility criteria before opening a case.

Complete the Level of Care determination

Use the state-required LOC assessment tool to document functional and medical criteria. The participant must meet nursing-facility-equivalent need for most 1915(c) waivers.

Issue service authorization

Determine the authorized hours per service type based on the LOC and available waiver benefits. Enter the authorization into the state Medicaid portal or MCO system.

Draft the Person-Centered Service Plan

Document participant goals, preferences, and backup plans. Obtain the participant's signature before services begin. The plan must comply with 42 CFR 441.301 PCSP requirements.

Verify agency EVV enrollment

Confirm the home care agency is enrolled with the state EVV aggregator. Verify the participant has a working app or telephony setup for visit check-in and check-out.

Reconcile authorized vs. delivered hours

Monthly, compare EVV-verified visit data against authorized units in the service plan. Flag over-utilization or under-utilization to the agency and document the conversation.

Conduct monitoring visit and trigger reauthorization

Complete the QA monitoring visit checklist. Initiate reauthorization 60 to 90 days before the plan period ends to avoid a gap in authorized services.

Set reauthorization calendar reminders

Create a calendar alert 90 days before each participant's plan end date. Missing the submission window can gap authorized services and disrupt caregiver scheduling.

Billing reconciliation is a federal expectation

Step 6 protects the audit trail. CMS expects authorized units and EVV-verified delivery to match before claims are paid, so reconcile every billing cycle.

Eligibility and LOC screeningService authorization issuedPCSP drafted and signedEVV enrollment confirmedBilling reconciliation monthlyReauthorization triggered at 90 days

Sources: 42 CFR 441.301 · How Medicaid pays home care agencies

What Must a Person-Centered Service Plan Include?

A PCSP must document the participant's goals, preferences, backup plans, risk assessments, informed consent, and all authorized services with hours per service type.

The HCBS Settings Final Rule (42 CFR 441.301, effective 2023 statewide) requires person-centered planning as a condition of federal waiver funding. The plan must reflect what the participant wants, not just what the provider offers.

Participant goals and preferences

Long-term goals, daily routines, and personal preferences documented in the participant's own words.

Backup support plan

Named backup caregiver or agency contact when the primary caregiver is unavailable or calls out.

Risk assessment and mitigation

Identified safety risks, fall hazards, medication management needs, and agreed mitigation steps.

Participant rights and informed consent

Documented explanation of rights, grievance process, and signed consent before services begin.

Authorized services and hours

Each service type listed with frequency, duration per visit, and total authorized units per plan period.

HCBS Settings compliance is non-negotiable

As of May 2023, CMS requires all waiver services to be in settings that are not institution-like. Settings that restrict participant choice or isolate participants from the community are prohibited.

Sources: 42 CFR 441.301 · CMS Settings Final Rule FAQ

How Often Does a Medicaid Waiver Need to Be Reauthorized?

Most 1915(c) waivers reauthorize annually; 1915(i), 1915(k), and MLTSS plans follow similar cycles with the exact window defined in each state's approved waiver plan.

Waiver Type	Typical Frequency	Key Required Docs	Recommended Lead Time
1915(c)	Annually (some states semi-annually)	Updated LOC + PCSP + incident log	90 days before end date
1915(i)	Annually	LOC reassessment + updated PCSP	60 days before end date
1915(k) CFC	Varies by state (6 to 12 months)	PCSP + functional assessment	60 days before end date
MLTSS	Per MCO contract (typically annual)	MCO care plan + LOC documentation	90 days before end date

Start the reauthorization process early

State portals lock submissions to defined windows. Submit 90 days early for 1915(c) and MLTSS; 60 days early for 1915(i) and 1915(k) to avoid service gaps.

90 daysRecommended 1915(c) lead time

12 monthsTypical maximum plan period

0 gapsGoal between plan periods

Sources: KFF HCBS Issue Brief · CMS Managed Care / MLTSS

What Is the Case Manager's Role in EVV Verification?

The case manager verifies monthly that agency EVV logs capture all six required data elements and that the participant's compliance rate meets the state threshold.

A woman wearing a white doctor's coat facing another woman during a one-on-one conversation in a healthcare office

CMS EVV mandate: six required data elements

The 21st Century Cures Act (2016) mandated EVV for all Medicaid personal care services. Every visit must capture six specific data elements to qualify for federal matching funds.

Type of service providedIndividual receiving serviceDate of serviceLocation of service deliveryCaregiver providing serviceVisit start and end time

Pull the monthly compliance report

Request the agency's EVV summary each month and confirm every required element was captured per visit.

Monthly cadencePer participant

Flag missing data elements

Identify visits that lack location, time, or caregiver identity, then require the agency to correct the record.

Manual editsAudit trail

Trigger corrective action under 90%

A compliance rate below the state threshold prompts a documented corrective action plan before the next billing cycle.

90% thresholdDocumented

Agencies running AveeCare surface the six-element compliance rate per participant, so the case manager's monthly verification becomes a single export review rather than a manual visit-by-visit reconciliation.

Sources: CMS EVV Technical Guide · EVV requirements by state

What Does a Case Manager Check During a Monitoring Visit?

During a monitoring visit, the case manager confirms the PCSP is current, EVV compliance is adequate, all incidents are closed, and caregiver credentials are valid.

A medical professional holding a stethoscope to the chest of a patient who is seated, performing a health assessment

Federal regulations require periodic monitoring to ensure services are delivered per the PCSP and that the agency meets quality standards. Most states require visits every six months for stable participants and more frequently after incidents.

Confirm PCSP is current and signed

Verify the plan on file matches what is being delivered. Collect an updated participant signature if the plan has changed since the last review.

Review EVV compliance rate

Pull the last 90 days of EVV visit data. Flag any visits missing required data elements and request an explanation from the agency for any compliance rate below 90%.

Review all incident reports

Confirm that every incident from the current period has been documented, investigated, and formally closed per state reporting requirements.

Verify caregiver credentials

Check that no certifications, background checks, or required training records have expired for any caregiver currently assigned to this participant.

Assess caregiver continuity

Review caregiver turnover on this participant's case. Excessive changes in assigned caregivers are a quality signal; discuss impact with the participant and family.

Compare authorized vs. delivered hours

Cross-reference the service plan's authorized units against actual EVV-verified hours. Consistent under-delivery may indicate scheduling gaps or unmet need.

Document findings and assign corrective actions

Complete the monitoring visit form. Assign corrective action items with specific deadlines for any deficiencies and schedule a follow-up if needed.

Agency preparation tip

Home care agencies using AveeCare can generate a monitoring-ready compliance summary showing EVV rates, caregiver credential status, and care-plan adherence in a single export before every monitoring visit.

7Items on the monitoring visit checklist

6 monthsTypical monitoring visit frequency

90%EVV compliance rate threshold to flag

Sources: HHS FY2024 HCBS Quality Measures · PMC HCBS Evolution Study · Evaluating agencies for waiver referrals · Supervisory visit documentation requirements

Frequently Asked Questions

Common questions from Medicaid waiver case managers and home care agency administrators.

Sources

1. CMS HCBS Home and Community-Based Services (accessed May 26, 2026)
2. CMS 1915(c) Waiver Authority (accessed May 26, 2026)
3. 42 CFR 441.301 HCBS Settings Final Rule (eCFR) (accessed May 26, 2026)
4. CMS HCBS Settings Final Rule FAQs (accessed May 26, 2026)
5. KFF: Medicaid Home and Community-Based Services (accessed May 26, 2026)
6. CMS Managed Care / MLTSS (accessed May 26, 2026)
7. HHS CIB FY2024 HCBS Quality Measures (accessed May 26, 2026)
8. CMS EVV Technical Guide (accessed May 26, 2026)
9. Home- and Community-Based Services: Evolution and Future Directions (PMC) (accessed May 26, 2026)

About the Author

Cal Nesvig

Founding Partner, AveeCare

Cal Nesvig is a founding partner at AveeCare, a home care software platform serving agencies across all 50 states. He focuses on Medicaid waiver compliance, EVV requirements, and agency operations.

Reviewed for accuracy; reviewer bio forthcoming. This article covers Medicaid waiver regulations and HCBS Settings Final Rule compliance.

Related Guides

Continue Reading

Clinical Guide

Infection Control Guide

Infection control assessment, pathogen reference, PPE selection tool, and training compliance tracker.

Read guide

50-State Reference

Background Check Requirements

State-by-state background check reference, cost calculator, compliance timeline, and disqualifying offense guide.

Read guide

State Requirements

Workers' Compensation Guide

Premium estimator, 50-state requirements reference, claims cost calculator, and safety ROI calculator.

Read guide

50-State Reference

Licensing Requirements by State

Interactive 50-state licensing reference with requirements, fees, processing times, and startup cost estimator.

Read guide

Security & Migration

Cloud-Based Home Care Software Guide

Cloud readiness assessment, security checklist, migration timeline planner, and cloud vs on-premise comparison.

Read guide

Browse all guides

Refer to an agency that stays audit-ready?

AveeCare gives home care agencies real-time EVV compliance dashboards, caregiver credential tracking, and monitoring-visit exports built for your review cycle.

See a free demo