Home Health Agency Requirements in Minnesota

Minnesota requires state licensure for all individuals and organizations offering home care services. The Minnesota Department of Health (MDH) administers two distinct license types based on service scope.

License Types and Requirements

Basic Home Care License ($2,100 annual fee): Covers non-medical supportive services including personal care assistance, homemaking, and companionship. Agencies providing only personal care services typically qualify for this license category.

Comprehensive Home Care License ($4,200 annual fee): Required for agencies providing skilled nursing, therapy services, or any clinical care. This license mandates employment or contract with a qualified Registered Nurse (RN) or other Licensed Health Professional (LHP) for supervision, training, and delegation of care tasks. Only comprehensive licensees are eligible for Medicare certification.

Application and Approval Process

Minnesota's licensing process requires:

  • Comprehensive agency-specific policies and procedures addressing all home care statutes
  • MDH review of applicant knowledge and regulatory compliance
  • Potential telephone or in-person meeting with MDH representatives
  • 60-day review period once application is deemed complete
  • Initial temporary license followed by full survey for compliance verification

Integrated License Option

Minnesota offers an integrated license that allows home care licensees to provide basic support services under Minnesota Statutes section 245D.03. This integration supports agencies serving home care clients who wish to also offer support services as part of broader care plans without obtaining separate licensure.

Key governing statutes include Minnesota Statutes 144A.43-144A.484 (Home Care), 144D and 144G, and 626.556-626.5572 (Vulnerable Adults/Maltreatment reporting).

Certified Nursing Assistant (CNA) Certification

Minnesota's Nurse Aide Registry, maintained by MDH, certifies CNAs who complete approved training and demonstrate competency through standardized testing.

Training Requirements

Minnesota-approved CNA training programs require:

  • Minimum 75 hours of curriculum covering basic nursing care, infection prevention, communication, patient safety, and emergency protocols
  • At least 16 clinical hours of hands-on instruction at a licensed nursing home under supervision
  • Background check completion prior to course enrollment and employment

The Minnesota State Health Care Core Curriculum/Nursing Assistant (HCCC/NA) program requires 128 hours of training—the most comprehensive option available.

Examination Requirements

The National Nurse Aide Assessment Program (NNAAP) examination consists of:

  • Written knowledge test: Available in English, Spanish, Somali, and Hmong (as of January 27, 2025)
  • Manual skills demonstration: Hands-on competency evaluation
  • Up to three testing attempts within two years of training completion
  • Candidates failing one section may retest only that portion

Renewal Requirements

CNAs must demonstrate 8 hours of nursing or nursing-related duties every 24 months to maintain active registry status.

Free Training Provision

Nurse Aides employed by or with offers of employment from certified nursing homes or boarding care homes prior to beginning training may not be charged for any portion of the training program or competency evaluation.

Home Health Aide (HHA) Certification

Minnesota offers a distinctive combined certification pathway that streamlines workforce entry for home health care.

Combined NA/HHA Certification

The Minnesota Department of Health provides an opportunity to take one examination that certifies individuals as both a Nursing Assistant (NA) and Home Health Aide (HHA). This combined program reduces credentialing barriers and expands employment flexibility across settings.

Pathway for Existing CNAs

CNAs certified through state-approved programs who passed the NNAAP assessment need only complete the written portion of the NA/HHA examination after finishing home health aide training—the skills portion is waived.

Federal Requirements

Medicare-certified home health agencies must ensure HHAs meet federal requirements including 75 hours of training with supervised practical experience and competency evaluation in required skill areas.

Minnesota Medicaid and Home Care Services

Minnesota Health Care Programs (MHCP) provide comprehensive home care coverage through Medical Assistance (MA), the state's Medicaid program.

2026 Financial Eligibility

For HCBS waiver programs:

  • Asset limits: $3,000 for single applicants; $6,000 combined for married couples
  • Income limit: $2,998 per month for single applicants
  • Medically Needy: $1,305/month individual, $1,764/month couple (July 2025-June 2026)

Covered Home Care Services

Minnesota Medicaid covers a broad range of home health services including:

  • Skilled nursing (RN and LPN)
  • Home health aide services
  • Physical, occupational, and speech therapy
  • Medical social services
  • Extended home care services (extended PCA, extended HHA, extended nursing)

Reimbursement Updates for 2025-2026

The 2025 legislative session made several adjustments to HCBS rates:

  • Provider rates increase 4% (reduced from the typical 6% to manage budget constraints)
  • $141 minimum daily rate for 24-hour customized living services effective January 1, 2026
  • Rate adjustments apply to Elderly Waiver qualified facilities

HCBS Waiver Programs

Minnesota operates multiple Home and Community-Based Services waiver programs serving different populations with varying needs.

Elderly Waiver (EW) and Alternative Care (AC)

The Elderly Waiver and Alternative Care programs fund HCBS for people 65 and older who require nursing home level of care but choose community living. These programs provide services and supports to delay or prevent nursing facility placement.

Disability Waivers

  • Brain Injury (BI) Waiver: Specialized services for individuals with acquired brain injuries
  • Community Alternative Care (CAC): Serves individuals who would otherwise require hospital-level care
  • Community Access for Disability Inclusion (CADI): Broad services for physical disabilities and chronic conditions
  • Developmental Disabilities (DD) Waiver: Comprehensive supports for developmental disability populations

Important Waiver Characteristics

Key considerations for agencies:

  • HCBS waivers are not entitlements—participant numbers are limited and waiting lists may exist
  • Services may be provided at home, adult day care, adult foster care, or assisted living settings
  • Each waiver has specific application processes, eligibility requirements, and covered services
  • Federal budget considerations may affect future waiver availability and funding levels

In-Home Support Changes (2026)

Starting January 1, 2026, In-Home Support (IHS) with training allows up to six hours per day, with billing limited to no more than three consecutive hours at a time.

Personal Care Assistance and CFSS Transition

Minnesota's Personal Care Assistance (PCA) Program is undergoing a significant transformation that agencies must understand and navigate.

Community First Services and Supports (CFSS)

The PCA Program began transitioning to CFSS on October 1, 2024. This transition will continue for approximately one year to ensure service continuity for current PCA beneficiaries.

Program Features

Both PCA and CFSS provide:

  • Assistance with daily living activities (bathing, dressing, mobility, cooking, eating, shopping)
  • Lower eligibility threshold than most waiver programs—requires assistance with only one ADL or qualifying behavior (no NFLOC requirement)
  • Compatibility with Elderly Waiver—individuals can receive services from both programs simultaneously

Agency Implications

The CFSS transition introduces self-direction options that may affect traditional agency service models. Agencies should:

  • Understand CFSS service delivery models and billing requirements
  • Prepare for potential shifts in how personal care services are authorized and provided
  • Maintain communication with current PCA clients about transition timelines and options

Electronic Visit Verification (EVV)

Minnesota implements EVV requirements in compliance with the 21st Century Cures Act for personal care services and home health services requiring in-home visits.

Required Data Elements

Minnesota's EVV system captures:

  • Type of service performed
  • Individual receiving the service
  • Date and location of service delivery
  • Individual providing the service
  • Time service begins and ends

Compliance Considerations

Agencies must ensure EVV integration with their scheduling and billing systems. The state provides approved EVV vendor options and technical assistance for implementation.

Medicare Home Health in Minnesota

Medicare-certified home health agencies in Minnesota must maintain both federal certification and state licensure.

Dual Compliance Requirements

All federally certified HHAs must hold a Minnesota comprehensive home care license. Key requirements include:

  • Comprehensive license holders only are eligible for Medicare certification
  • Temporary licensees and basic licensees cannot pursue Medicare certification
  • Initial full survey demonstrating substantial compliance required before certification

PDGM Considerations

Minnesota agencies operate under the Patient-Driven Groupings Model (PDGM) with 30-day payment periods. Success requires accurate coding, efficient visit utilization, and strong clinical documentation.

Minnesota Labor Laws for Home Care

Minnesota's labor environment features some of the nation's most progressive home care worker protections, including historic wage agreements and new paid leave requirements.

Minimum Wage Schedule

Location/Category 2025 Rate 2026 Rate
State minimum (all employers) $11.13/hour $11.41/hour
Minneapolis city $16.37/hour $16.37/hour+
St. Paul city $13.25/hour Higher (phased)
Training wage (under 20, 90 days) $9.08/hour $9.31/hour

Note: When multiple rates apply, employers must pay the higher rate.

Home Care Worker Wage Agreement

Minnesota's historic home care contract established landmark wage improvements:

  • Base wages increased from $15.25 to $20 per hour for all home care workers by 2025
  • Experience-based wage scale with senior caregivers earning up to $22.50 per hour
  • These rates apply to state-contracted home care services and set market expectations

Overtime Requirements

Minnesota overtime rules differ from federal standards:

  • State law: 1.5x regular rate after 48 hours per workweek
  • Federal (FLSA): 1.5x after 40 hours per workweek (applies to covered employers)
  • Live-in employees: Overtime after 48 hours per workweek
  • Agencies must comply with the standard providing greater worker benefit

Paid Family and Medical Leave (Effective January 1, 2026)

Minnesota's comprehensive paid leave program significantly impacts home care employers:

  • Benefit: Up to 12 weeks of paid family leave at 80-100% wage replacement
  • Funding: 0.7% payroll tax split equally between employers and employees
  • Effective date: Contributions and benefits began January 1, 2026
  • Notice requirement: Written notice to employees within 30 days of start date or 30 days before January 1, 2026

Earned Sick and Safe Time

Minnesota's statewide earned sick and safe time law requires employers to provide paid time off for illness, safety needs, and care of family members. Home care agencies must track and provide this benefit.

Workers' Compensation

Household employers (including home care agencies placing workers in private homes) must maintain workers' compensation coverage for any worker earning more than $1,000 in any quarter.

Nursing Home Workforce Standards Board

Minnesota established a Nursing Home Workforce Standards Board with authority to set minimum wage and working condition standards for nursing home workers.

Current Status

Minimum wage standards for nursing home workers require federal CMS approval of associated rate increases before becoming effective. As of December 2025, CMS had not yet approved the rate increase, delaying implementation to 30 days after approval is obtained.

Implications for Home Care

While focused on nursing homes, these standards may influence home care wage expectations and create competitive pressures in the broader direct care workforce market.

Workforce Challenges and Strategies

Minnesota agencies face distinct workforce dynamics shaped by progressive labor policies, diverse populations, and geographic factors.

Key Challenges

  • Wage competition: State-contracted home care rates and Minneapolis local minimums set high wage floors
  • Administrative burden: Paid leave, sick time, and EVV compliance require robust systems
  • Geographic disparities: Rural areas face severe shortages despite statewide recruitment efforts
  • CFSS transition uncertainty: Self-direction options may shift workers away from traditional agencies
  • Multilingual workforce needs: Diverse populations require cultural competency and language accessibility

Effective Strategies

  • Embrace wage transparency: Communicate competitive wages and experience-based increases clearly in recruitment
  • Leverage combined certification: Promote NA/HHA combined credentialing to maximize worker flexibility
  • Invest in multilingual testing preparation: Support workers accessing exams in Spanish, Somali, and Hmong
  • Prepare for paid leave: Build coverage depth to maintain service continuity during leave absences
  • Rural recruitment initiatives: Partner with community colleges and workforce centers in greater Minnesota
  • Technology adoption: Implement integrated systems for EVV, scheduling, and payroll to manage compliance efficiently

Retention Best Practices

  • Experience-based wage scales matching or exceeding state contract rates
  • Clear advancement pathways from HHA to LPN to RN
  • Cultural competency training and diverse leadership development
  • Flexible scheduling respecting earned sick and safe time rights
  • Recognition programs celebrating worker contributions and longevity

Resources and Links

The Bottom Line

Minnesota's home health care environment reflects the state's progressive policy approach with some of the nation's highest direct care worker wages, comprehensive paid leave benefits, and multilingual testing accessibility. Agencies succeeding in the North Star State embrace these worker-friendly policies as competitive advantages rather than burdens. Understanding the MDH licensing structure, combined NA/HHA certification pathway, CFSS transition, and 2026 paid leave requirements positions agencies to build stable workforces and deliver quality care across Minnesota's diverse communities.

Struggling with Workforce Challenges?

Home Health Workforce specializes in solving the unique staffing problems Minnesota home health agencies face. Let's discuss how we can help you build a reliable care team.

Get in Touch