CFSS billing follows one rule that explains most denials: Minnesota Health Care Programs (MHCP) pays only for services that are on a lead agency service authorization, were actually delivered, and were documented before the claim was submitted. Community First Services and Supports (CFSS) replaced Personal Care Assistance (PCA) for transitioning participants on October 1, 2024, and while the base personal care code stayed T1019, the authorization, the modifiers, and the supporting records changed.
This guide is for agency-model providers and walks the claim in order: the service authorization, the code table, 15-minute units, electronic visit verification (EVV) as a precondition, MN-ITS submission and remittance, common denials, and DHS pre-payment review. It reflects MHCP guidance as of September 2026; rates are published in the DHS rate tables and not stated here.
If your agency is still moving participants over, read the PCA to CFSS transition guide first, since the enrollment record has to be right before anything in this article works.
The service authorization comes first
Every CFSS service requires a lead agency assessor to complete a service authorization (SA). The lead agency is the county, Tribal nation, or managed care organization that assessed the participant. For the agency model it authorizes units; for the budget model it authorizes dollars to a financial management services (FMS) provider.
The authorization arrives as a service authorization letter (SAL) in the SAL folder of your MN-ITS mailbox. Four things have to be true for the authorization to turn into payment:
- Your agency is actively enrolled and has current credentials (liability insurance, surety bond, fidelity bond, workers' compensation) on the provider record.
- The participant keeps MHCP eligibility. Verify it every month through the eligibility verification system (EVS) by phone or in MN-ITS.
- The SAL is accurate. Providers are responsible for checking it on receipt and asking the lead agency to correct it.
- The service was delivered on a date inside the authorization period and documented.
An approved authorization is not a guarantee of payment. If a participant switches models mid-year, a revised service delivery plan goes to the lead agency, which updates the authorization or sends the CFSS Request Form (DHS-6893I) to DHS. Until the new SAL lands, bill only the dates the old one covers. The agency model vs budget model comparison explains what changes on the authorization when a participant switches.
CFSS billing codes for the agency model
The table below lists the CFSS codes named in the MHCP CFSS billing pages and the IMCare CFSS provider manual (revised August 13, 2026). Modifiers for the enhanced rate, tiered rate, shared services, and spouse or parent-of-minor claims are set out in the "Agency Model HCPCS Procedure Code and Modifiers" table in the MHCP manual. Check that table for the current combinations rather than copying modifiers from old PCA claims.
| Code | Service | Unit | Who bills |
|---|---|---|---|
| T1019 | CFSS personal care (agency and budget model) | 15 minutes | CFSS provider agency (agency model); FMS provider (budget model) |
| T1023 | CFSS consultation services | 1 session; maximum six sessions per service authorization | Consultation services provider |
| S5116 | CFSS worker training and development budget | Per the authorization | CFSS provider agency or FMS provider |
| T5999 | Goods and services | Per the authorization | FMS provider only |
| T2040 | FMS fee; failed background study | Per the authorization | FMS provider |
| S5160, S5161, S5162 | Personal emergency response system install, monitoring, and equipment | Per the authorization | PERS provider |
From the MHCP T1019 billing page:
- Enter one service line per date of service, per procedure code and modifier combination.
- Add the rendering CFSS worker's unique Minnesota provider identifier (UMPI) or national provider identifier (NPI) on each line. A worker not enrolled and affiliated on that date causes the line to deny. The CFSS support worker requirements guide lists what must be in the worker file before that date.
- The enhanced rate is paid only when the worker who delivered the service has completed the qualifying trainings and the agency has verified that in the DHS system. Otherwise DHS pays the base rate.
Two more rules trip up agencies coming from PCA. First, the U2 modifier that PCA agencies must use for services by a spouse or parent of a minor is not used on CFSS claims. Second, background studies cannot be billed under the agency model; only FMS providers in the budget model may include that cost on a T1019 claim.
Shared services (one worker, two or three participants, same time and place) pay one and one-half times the single rate for two participants and no more than two times for three, under § 256B.85. A signed Home Care Shared Services Agreement (DHS-6893E) must be on file.
Units, tiers, and the training budget
One T1019 unit is 15 minutes of documented service. The lead agency sets a unit total for the authorization period based on the participant's home care rating under § 256B.85, subd. 8, and the schedule, the EVV clock times, and the claim have to agree on the units.
Agency-model rates are tiered by the worker's cumulative PCA and CFSS hours since July 1, 2017; the tiers and current rate limits are on the Long-Term Services and Supports Service Rate Limits (DHS-3945), and the Tiered Wage PCA/CFSS list in MN-ITS shows each worker's tier. Under § 256B.851, the retention increase must be passed through to wages and wage-related costs.
The worker training and development budget (S5116) is new with CFSS. The lead agency authorizes it for every participant using T1019, and the agency can use it for training, observation, monitoring, and coaching of workers by the supervising professional. Keep a record of what each S5116 claim paid for.
Audit tip: units are compared to clock times, not to the schedule. If a worker's EVV visit shows 2 hours 10 minutes and the claim bills nine units, the ninth unit is an overpayment. Round according to the MHCP billing policy for 15-minute units and let the system compute units from the verified times.
EVV is a billing precondition
CFSS agency and budget model personal care has been an in-scope EVV service since October 1, 2024. As of January 1, 2026 every provider subject to the federal 21st Century Cures Act must be enrolled with HHAeXchange, the state aggregator, regardless of the EVV system or payer it uses, and must submit data for every visit, including visits that are not fully compliant. Providers must meet at least 50 percent EVV compliance for visits billed after January 1, 2026 and at least 80 percent for visits billed after July 1, 2026. Manually entered or edited visits count against the rate.
HHAeXchange emails a monthly compliance report around the 25th of each month covering the previous month, and DHS receives the same report. Providers under the threshold receive a notice of corrective action in the PRVLTR folder of the MN-ITS mailbox. A notice can require a compliance target by a deadline, a written improvement plan, or a meeting with DHS, and if the provider does not respond or improve, DHS may recover payments already issued or withhold future payments.
The Minnesota EVV requirements guide explains the thresholds and what a compliant visit looks like.
Submitting the claim: MN-ITS, 837P, and the 835 remittance
CFSS agency providers bill MHCP on the professional claim format: direct data entry in MN-ITS, an 837P batch upload, or a clearinghouse. Keep your MN-ITS mailbox active in every case; DHS sends service authorization letters, corrective action notices, and cost reporting memos there and nowhere else.
Payment and denial detail come back on the 835 electronic remittance advice, with claim adjustment reason codes on each line. Reconcile the 835 within the week it arrives, because the appeal clocks run from the remit date. Health plan appeals generally must be filed within 60 days of the remit date; verify the fee-for-service timely filing limit in the MHCP Provider Manual billing policy chapter before relying on a number.
Managed care changes the destination, not the rules. Participants aged 65 and older in Minnesota Senior Health Options (MSHO) or Minnesota Senior Care Plus (MSC+) are billed to the health plan; participants aged 64 and under are carved out and billed fee-for-service to MHCP.
Common CFSS denial reasons and how to prevent them
| Denial reason | What usually happened | Prevention |
|---|---|---|
| No authorization on file | Service date outside the SAL period, or the SAL is for a different model or provider | Check the SAL folder weekly; block scheduling outside the authorization window |
| Units exceed authorization | Cumulative units passed the period total, often from overlapping shifts or unrounded times | Track remaining units in real time; compute units from EVV clock times |
| Participant not eligible | Eligibility lapsed for the month | Run EVS or MN-ITS eligibility on the first business day of each month |
| Rendering worker invalid | Worker not enrolled, not affiliated, or affiliation ended before the service date | Gate scheduling on an active UMPI and affiliation date |
| Provider credentials expired | Surety bond, fidelity bond, insurance, or workers' compensation lapsed on the record | Track expiration dates 60 days ahead and upload renewals through MPSE |
| Modifier mismatch | Enhanced or tiered modifier used for a worker who has not qualified, or U2 carried over from PCA | Verify worker training status before applying rate modifiers |
| Duplicate service line | Two lines for the same worker, participant, and date | Combine same-day visits per code and modifier |
| EVV mismatch or noncompliance | Visit missing from HHAeXchange, manually entered, or times differ from the claim | Resolve HHAeXchange import rejections daily; bill from verified visits |
The MHCP claim denials guide covers how to read the adjustment codes and build an appeal packet for the ones that get through.
Pre-payment review and the records behind the claim
PCA and CFSS are among the 14 high-risk services that DHS subjects to pre-payment review as of September 2026. On review, claims are held and the agency is asked to produce records before payment. The IMCare CFSS manual, which mirrors the MHCP manual, lists what a CFSS provider agency must have in its records before submitting any claim:
- A copy of the CFSS assessment (DHS-6893A) or the MnCHOICES assessment information.
- The service delivery plan and the lead agency addendum.
- The service authorization.
- Time and activity documentation for every worker who served the participant, captured through EVV or on the DHS-6893C template.
- Worker training and supervision records, including competency visits.
- Evaluations of the CFSS service and the service delivery plan.
- The written agreement signed by the agency and the participant or representative, plus the DHS-6893F responsible party form where one applies.
- The DHS-6893E shared services agreement, if applicable.
For what to look for in a system that keeps these records together, see the PCA and CFSS agency software guide.
How Trustora helps
Trustora builds the CFSS claim from the verified visit. The caregiver app records GPS clock-in and clock-out and the participant's signature, the visit goes to the HHAeXchange aggregator, and units are computed from the verified times. Before a T1019 line is released, the pre-claim gate checks the service authorization period and remaining units, the participant's eligibility for the month, the rendering worker's enrollment and affiliation dates, the agency's credential expiration dates, and the modifier against the worker's training status.
Claims go out as 837P files, and the 835 remittance is reconciled automatically so denied lines land in a work queue with the adjustment reason attached and an appeal packet ready to assemble. Participant records hold the assessment copy, the service delivery plan, the authorization, and the signed agreements, so a pre-payment review request can be answered from the audit binder. See the features page for the full claims lifecycle.