PCA to CFSS transition: what Minnesota agencies must do by Sept 30, 2027

The PCA to CFSS transition is the largest change to Minnesota's home care program in a generation. Community First Services and Supports (CFSS) replaced Personal Care Assistance (PCA) and the Consumer Support Grant (CSG) for new and transitioning participants on October 1, 2024. Every person still on PCA or CSG must be moved to CFSS no later than September 30, 2027.

For an agency, the question is not whether to transition but how fast. The service your workers deliver looks similar, but the enrollment record, the plan of care, the worker supervision rules, and the billing codes all change. CFSS is governed by Minn. Stat. § 256B.85, with payment rates in § 256B.851.

This guide covers what CFSS is, the dates, the two service models, what a PCA agency must file, the worker competency rules, and how a participant moves, as of September 2026. Families and workers who need the program explained from the start can read what CFSS is first.

What is CFSS and how is it different from PCA?

CFSS is a Medical Assistance state plan service that pays for help with activities of daily living, instrumental activities of daily living, health-related tasks, and observation and redirection of behavior. That is the same core as PCA. The differences are in who controls the service and what else the authorization can pay for.

Two statutory rules are new for a PCA agency. Under § 256B.85, subd. 11, an agency provider must use at least 72.5 percent of its CFSS revenue on support worker wages and benefits, and the statute bans noncompete clauses that restrict a worker from serving the same participant through another agency or FMS provider.

Key dates: October 2024 to September 30, 2027

Most participants transition at their annual reassessment, so an agency's caseload moves in a rolling fashion over the whole window, and the last year before the deadline is when the remaining volume lands.

Agency model vs budget model

The participant chooses the model, and can switch by updating the service delivery plan with a consultation services provider and getting lead agency approval.

Agency model. The lead agency (county, Tribal nation, or managed care organization) authorizes units to a CFSS provider agency. The agency recruits, hires, trains, supervises, and pays support workers, and monitors the service delivery plan with the participant. Rates are tiered by the worker's cumulative PCA and CFSS hours since July 1, 2017, and the increase must go to wages and wage-related costs. Agency-model workers are not covered by the SEIU contract.

Budget model. The lead agency authorizes dollars. The participant is the employer, and an FMS provider handles payroll, taxes, and employer paperwork. Budget-model workers are covered by the SEIU contract and the tiered minimum wage schedule. A participant who leaves the budget model cannot return to it until the next service plan year. The agency model vs budget model comparison lays the two models side by side for participants and agencies.

What a PCA agency must do to become a CFSS agency provider

The full steps are on the DHS "CFSS provider agency enrollment criteria and forms" page. Enrollment goes through the Minnesota Provider Screening and Enrollment (MPSE) portal or by fax, and DHS asks providers to allow 30 days for processing.

Training: the CFSS transition test or Steps for Success

An existing PCA agency completes the CFSS transition test. A new agency, or one whose Steps for Success certificate does not carry the CFSS title, completes the PCA/CFSS Steps for Success workshop with "CFSS" on the certificate.

Forms: DHS-8160A and DHS-8560

• CFSS Agency Provider Agreement Addendum (DHS-8160A). The addendum to your existing MHCP provider agreement that adds CFSS to your enrollment record.
• CFSS Agency Assurance Statement (DHS-8560). The signed statement that the agency meets the § 256B.85 agency provider standards, including the wage-and-benefit floor and worker supervision rules.

Credentials on the provider record

§ 256B.85, subd. 12 sets the financial credentials. As of September 2026 the statute requires a surety bond of $50,000 for a new agency or one with Medicaid revenue at or below $300,000 in the previous year, and $100,000 above that; a fidelity bond of $20,000 per provider location; workers' compensation coverage; and liability insurance. MHCP will not pay a provider whose credentials have lapsed on the enrollment record, so track the expiration dates.

Supervising professional

A CFSS agency must employ or contract with a supervising professional who holds the appropriate license or certification. The supervising professional runs the competency visits, the service evaluations, and the worker training and development budget. Confirm the license is current on the provider record.

Cost report

Agency-model providers complete the CFSS cost report when DHS selects them. The selection memo goes to the PRVLTR folder in the agency's MN-ITS mailbox, so check that mailbox weekly.

Compliance note: new CFSS agency enrollment has been in the DHS enrollment freeze since January 27, 2026, and the pause was extended through January 27, 2027. Existing enrolled providers continue to serve clients. If you are a PCA agency that has not yet filed the CFSS addendum, call the MHCP Provider Resource Center to confirm how the freeze applies to you before you assume the addendum will be processed. The Revalidate 2026 and enrollment freeze guide has the full list of affected services.

Worker requirements: enrollment, training, and competency visits

CFSS support workers are individually enrolled with MHCP and affiliated with the agency, the same as PCA workers. Before affiliating a worker the agency must confirm that the person:

1. Meets the Direct Support Worker individual enrollment criteria.
2. Has completed the individual PCA and CFSS training. DHS requires workers whose PCA training certificate is dated before April 15, 2020 to obtain a new certificate.
3. Is not on the federal Office of Inspector General exclusion list.
4. Has a completed background study through NETStudy 2.0 under Minn. Stat. ch. 245C, as required by § 256B.85, subd. 10.

Once the worker starts, the supervision schedule begins. § 256B.85, subd. 11b requires the agency to verify by direct observation, within 30 days of the worker starting, that the worker is competent to meet the participant's assessed needs, to keep evidence of competency, and to complete a performance review at least annually. 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. The supervising professional also evaluates the CFSS service and plan within the first 90 days and at least quarterly.

Every visit is a dated record in the worker file, and DHS checks the competency log against the claim dates for that worker.

How participants move from PCA to CFSS

The participant's path has six steps; the agency is involved in the last two.

1. Assessment. The participant asks their lead agency for a CFSS assessment, or the lead agency offers one at the annual reassessment. The lead agency must complete the MnCHOICES assessment within 20 business days of the request. The assessor determines whether the person needs a participant representative and the amount of units or dollars.
2. Consultation. After the assessment, the participant chooses a CFSS consultation services provider, who explains the two models and helps write the plan. Up to six sessions are approved per service authorization.
3. Service delivery plan. The participant or representative writes the person-centered service delivery plan required by § 256B.85, subd. 6. It names the authorized services, the person's goals and preferences, and the amount and frequency of face-to-face and remote supports.
4. Approval. The consultation provider submits the plan to the lead agency, which approves it through a service delivery plan addendum.
5. Service authorization. The lead agency creates the service agreement. The agency receives the service authorization letter in the SAL folder of its MN-ITS mailbox.
6. Service starts. The agency signs a written agreement with the participant, files the DHS-6893F responsible party form where one applies, and begins delivering and documenting CFSS.

Before the first claim goes out, the agency record must hold the assessment copy, the service delivery plan and addendum, the service authorization, the signed agreement, and the worker's training and competency records. The CFSS billing guide lists the code table and pre-claim checks.

Billing and EVV during the transition

An agency serving both PCA and CFSS participants runs two code sets side by side. Personal care under both is billed as T1019 in 15-minute units with the rendering worker's UMPI or NPI, but the modifiers differ, and the CFSS authorization carries a separate worker training and development budget (S5116).

Electronic visit verification (EVV) applies to both. As of January 1, 2026 every provider must be enrolled with HHAeXchange regardless of the EVV system it uses, and since July 1, 2026 at least 80 percent of billed visits must be EVV compliant. The Minnesota EVV requirements guide explains the thresholds and corrective action process.

PCA and CFSS are also among the 14 high-risk services subject to DHS pre-payment review, so the documentation above has to exist on the day the claim is submitted. If you are choosing a system to run CFSS on, the PCA and CFSS agency software guide lists what to evaluate, and agencies that are just forming should start with how to start a home care agency in Minnesota.

How Trustora helps

Trustora runs PCA and CFSS on the same platform, so an agency can carry both code sets through the transition window without a second system. Each participant record holds the service authorization, the service delivery plan and addendum, the signed participant agreement, and the assessment copy, and the pre-claim compliance gate blocks a T1019 claim when any of them is missing or the units exceed the authorization. Worker files track training certificates, background studies, and the 30-day and 90-day competency visits with alerts before a visit is due.

The caregiver app on iOS and Android captures GPS clock-in and clock-out and the client's signature, and sends visits to the HHAeXchange aggregator so the EVV rate is measured in the same place the claim is built. See the platform overview for the scheduling, claims, and audit binder features that support a CFSS agency.