CFSS support worker requirements: training, background studies, competency

CFSS support worker requirements in Minnesota are set by Minn. Stat. § 256B.85, subd. 16: a Community First Services and Supports (CFSS) support worker must pass a background study under chapter 245C, complete the Minnesota Department of Human Services (DHS) standardized training and certification test, enroll with DHS, and complete employer-directed orientation on the participant's individual needs. Once the worker starts, the agency must verify competency by direct observation within 30 days and review performance at least annually.

Those are the statutory minimums. On top of them sit DHS guidance (competency visits every 90 days, in person during the first year), the Minnesota Health Care Programs (MHCP) enrollment record, the rules on which family members can be paid, the 310-hour monthly cap, and the 72.5 percent wage floor.

This guide is for agency-model providers and lists each requirement with its source, the worker file, and how to track expirations, as of September 2026. For the program itself, see what CFSS is; for how the worker rules differ when the participant is the employer, see the agency model vs budget model comparison.

What § 256B.85, subd. 16 requires of a support worker

One point agencies ask about: the statute in force as of September 2026 sets no minimum age for a CFSS support worker. Subd. 11b only requires that a minor worker's competency evaluations be done in person, so check the current DHS CFSS policy manual for any age rule applied at enrollment. Under subd. 16(b), DHS may deny or terminate enrollment for failing subd. 16(a), not providing authorized services, intoxication or drug activity in the participant's home, or exclusion by DHS or the federal Office of Inspector General (OIG).

The DHS standardized training and certification test

Subd. 16(a)(4) lists what the training must cover: basic first aid, vulnerable adult, child maltreatment, OSHA universal precautions, basic roles and responsibilities of support workers including body mechanics, emergency preparedness, orientation to positive behavioral practices, orientation to responding to a mental health crisis, fraud issues, time cards and documentation, and an overview of person-centered planning and self-direction. The training must be offered in other languages and with accommodations for disabilities.

DHS delivers the individual PCA and CFSS training and test online, and both are free. The worker may repeat the training as needed, then must pass the certification test, and the certificate goes in the enrollment packet. DHS requires workers whose PCA training certificate is dated before April 15, 2020 to obtain a new certificate, so check the date on an experienced PCA's certificate, not just that one exists. The agency then provides and documents the participant-specific orientation required by subd. 16(a)(5).

Background studies under chapter 245C

A CFSS worker cannot be enrolled until the background study is complete. The agency initiates the study through NETStudy 2.0 under chapter 245C, and the worker may start only after DHS issues a notice that the worker is not disqualified under § 245C.14, or is disqualified with a set-aside under § 245C.22. Subd. 10 requires agencies and FMS providers to "maintain documentation of background study requests and results."

Subd. 16a allows a narrow continuity-of-care exception: a worker already serving a participant may move to a different agency or FMS provider on initiation, rather than completion, of a new study, when DHS finds the change necessary for the participant's health and safety and the receiving provider meets the conditions in that subdivision. Under subd. 24, agency owners with a five percent or greater interest and all managing employees also need background studies.

Enrolling the worker with MHCP

A CFSS support worker is enrolled individually with MHCP as a direct support worker and affiliated with the agency through the Minnesota Provider Screening and Enrollment (MPSE) portal, and MHCP assigns the worker a unique Minnesota provider identifier (UMPI). Before affiliating a worker, the agency confirms the enrollment criteria, the current training certificate, the cleared background study, and a clean OIG exclusion check. The UMPI, or the worker's national provider identifier (NPI), is the rendering provider on every T1019 claim line, and a claim dated outside the affiliation period denies.

Competency: the 30-day observation, 90-day visits, and annual review

Subd. 11b is the agency's supervision rule. The agency must evaluate competency "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" the worker beginning to serve a participant or beginning shared services. The clock runs per participant, not per hire.

Subd. 11b(b) lists the evidence to keep: the worker's relevant education and experience, training from other sources, orientation to the participant's plan and preferences, qualified orientation for tracheostomy suctioning and ventilator support where they apply, and the periodic performance reviews. All of it must be dated.

Audit tip: a DHS reviewer lays the competency log next to the worker's claim history. The first observation must fall within 30 days of the first billed visit for that participant, and the 90-day visits must continue at that cadence. A gap in the log after a busy quarter is a common finding, because the visits happened and were never written down.

Who cannot be paid, and the family hour limits

Subd. 7(9) makes CFSS provided by "a parent, stepparent, or legal guardian of a participant under age 18, or who is the participant's spouse" a covered service, subject to the limits in subd. 7b:

• A single parent providing CFSS to a minor child or children may provide up to 60 hours of Medical Assistance home and community-based services in a seven-day period, regardless of the number of children.
• When multiple parents are support workers for their minor children, each parent may provide up to 40 hours in a seven-day period.
• A participant's spouse may provide up to 60 hours in a seven-day period.
• The limits do not raise the participant's authorization, and a parent or spouse may not be paid above the current support worker rate.

Subd. 9(18) lists "CFSS provided by a participant's representative or paid legal guardian" as noncovered, so a person cannot be both the representative and a paid worker, and subd. 9(34) excludes a provider who owns or controls the participant's living arrangement unless related by blood, marriage, or adoption or a qualifying foster care provider. Unlike PCA, no U2 modifier is used on CFSS claims for family workers; the CFSS billing guide covers the modifier table.

Shared services, the 310-hour cap, and the enhanced rate

Shared services means the same worker serving two or three participants at the same time, in the same setting, through the same agency or FMS provider, under a written agreement (subd. 2(x) and 11(d)). A signed Home Care Shared Services Agreement (DHS-6893E) must be on file, and the worker needs a separate 30-day competency observation when shared services begin. The 310-hour cap in subd. 16(d) applies "regardless of the number of participants the support worker serves or the number of agency-providers or participant employers" paying the worker, so ask about other employers at hire and at each review.

Subd. 16(f), effective January 1, 2026 or on federal approval, ties the enhanced rate to the worker: the participant must qualify for ten or more hours per day of CFSS, and the worker must meet the Medicare training and competency requirements for home health aides or nursing assistants, or a state-approved alternative. Bill the enhanced modifier only after verifying the training in the DHS system, and record the verification date.

The 72.5 percent wage floor

Subd. 11(e) requires an 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," and to document how it meets that requirement. Revenue from a collective bargaining rate increase must go entirely to wages and benefits, worker training and development revenue is excluded from the calculation, and the agency may not require a worker to sign a noncompete. A monthly report comparing CFSS revenue to wages and benefits paid is the simplest evidence.

The worker file an agency must keep

How to track expirations

Each item above either expires or starts a clock. Record the date when the document is filed, compute the next due date (30 days from the start of service, 90 days from the last visit, one year from the last review), and run one weekly report that answers two questions: which workers have a visit or review due in the next 14 days, and which workers billed on a date when a credential, affiliation, or background study was not current. The PCA and CFSS agency software guide turns those questions into demo tests, and the EVV compliance checklist covers the parallel weekly review for visit capture.

How Trustora helps

Trustora's worker file holds every item in the table above with a date: the background study result, the training certificate and its date, the OIG check, the MHCP enrollment and affiliation dates, the per-participant orientation, and the 30-day and 90-day competency visits with who observed and what was observed. Due dates are computed from the start of service, and the compliance engine alerts before a visit or annual review lapses.

The pre-claim gate checks the rendering worker's enrollment, affiliation dates, and training status before a T1019 line is released, so a claim cannot go out for a worker whose file is not current on that date. The one-click DHS audit binder assembles a worker's qualifications alongside the participant's record for any date range. See the features page for the scheduling, EVV, and payroll bridge that feed the wage-and-benefit report.