Overview of Minnesota Medicaid PCA / CFSS Programs
Minnesota’s Personal Care Assistance Program (PCA) will begin transitioning into a new program, the Community First Services and Supports Program (CFSS), on October 1, 2024. Personal care assistance provided under PCA will continue to be provided under CFSS. Intended to assist the elderly and disabled in living independently rather than require institutionalization (nursing home care), assistance with Activities of Daily Living (ADLs) and Instrumental Activities of Daily Living (IADLs) is provided. These activities include bathing, personal hygiene, dressing, mobility, cooking, eating, laundry, and shopping for essentials. The CFSS Program will allow program participants to select and purchase goods and services that enable independence. As an example, a program participant who requires a wheelchair might install a wheelchair ramp to access the home and add grab bars in the bathroom for safety.
For both the PCA Program and the CFSS Program, the program participant self-directs their care and chooses who will serve as their “support worker” (caregiver). This allows them to hire a relative or friend to provide care. Although many relatives, including an adult child, can be hired, a spouse or parent of a minor cannot be hired via the PCA Program. With CFSS, however, a spouse or a parent of a minor will be able to be hired. Persons who cannot direct their own care can have a representative do so on their behalf.
PCA and CFSS both offer two service delivery options, and regardless of which option is chosen, the program participant selects their own caregiver. In PCA, there is Traditional PCA and PCA Choice, and in CFSS, there is the Agency Model and the Budget Model. With Traditional PCA and the CFSS Agency Model, a provider agency is the “employer” and takes on all employment responsibilities. This includes hiring the “support worker” chosen by the program participant. With PCA Choice and the CFSS Budget Model, the program participant takes on a greater role and is the “employer”. The program participant hires and trains their “support worker”. However, a fiscal intermediary handles the financial aspects of employment responsibilities, such as tax withholding and caregiver payments, for the program participant.
Program participants must reside in their own home or the home of a friend or relative. It is thought that services can be provided to persons living in adult foster care homes, given there is a maximum of four residents, and assisted living residences.
PCA services are an entitlement, and CFSS services will be an entitlement once the program is implemented. “Entitlement” means meeting the state’s Medicaid eligibility requirements guarantees one will receive benefits. Put differently, there is never a waiting list for benefits.
The Personal Care Assistance (PCA) Program is a Medicaid State Plan program. It will be transitioning into another Medicaid State Plan program, Community First Services and Supports (CFSS). The Consumer Support Grant (CSG) is also transitioning into CFSS. Medicaid in Minnesota is called Medical Assistance (MA).
While home and community based services (HCBS) can be provided via a Medicaid Waiver or a state’s Regular Medicaid Plan, HCBS through Medicaid State Plans are an entitlement. Put differently, meeting the program’s eligibility requirements guarantees an applicant will receive benefits. On the other hand, HCBS via Medicaid Waivers are not an entitlement. Waivers have a limited number of participant enrollment slots, and once they have been filled, a waitlist for benefits begins. Furthermore, HCBS Medicaid Waivers require a program participant require the level of care provided in a nursing home, while State Plan HCBS do not always require this level of care.
Benefits of the PCA / CFSS Programs
The benefits available via PCA will continue to be available via CFSS and include the following.
– Behavior Observation / Redirection – watching for and redirecting behavior that is inappropriate and / or harmful
– Health-related Procedures / Tasks – i.e., medication assistance, range of motion / passive exercise, tracheostomy suctioning (caregiver must receive appropriate training)
– Personal Assistance Services – assistance with bathing, grooming, toileting, mobility, transferring (i.e., bed to a chair), preparing meals, shopping for essential items, paying bills, transportation, etc.
New supports will also be available via CFSS and include the following:
– Consultation Services – provides information about CFSS and a program participant’s choices, assists in creating one’s service delivery plan, and approves it
– Goods & Services – to aid in one’s independence (i.e., home modifications for safety and accessibility, personal emergency response system, microwave for cooking, assistive technology)
– Worker Training / Development Budget – for “support worker” (caregiver) training on a program participant’s specific needs (i.e., dementia care)
While it is thought that program participants can reside in adult foster care homes and assisted living residences, the cost of room and board is not covered.
Eligibility Requirements for PCA / CFSS Programs
The Personal Care Assistance Program, which will become the Community First Services and Supports Program, is for Minnesota residents who are chronically ill, disabled (physically or developmentally), or mentally ill. An applicant must be able to self-direct their own care or have a representative do so for them. As the PCA Program transitions into the CFSS Program, persons who are eligible for the Personal Care Assistance Program will continue to be eligible for the Community First Services and Supports Program. The criteria below is relevant for the elderly (65+ years of age).
Financial Criteria: Income, Assets & Home Ownership
Income
The applicant income limit is equivalent to 100% of the Federal Poverty Level (FPL). While this figure increases annually in January, the income limit for MN Medicaid increases each July. For elderly, blind, and disabled Medicaid, the effective income limit from 7/1/24 – 6/30/25 is $1,255 / month for a single applicant. Married couples, regardless of if one or both spouses are applicants, can have a monthly income up to $1,704.
With the CFSS Program, income will be calculated differently when just one spouse is an applicant. In this case, the non-applicant spouse’s income is disregarded, meaning it does not count towards the income eligibility of the applicant spouse. Furthermore, monthly income from the applicant spouse can be transferred to the non-applicant spouse as a Spousal Income Allowance, also called a Monthly Maintenance Needs Allowance.
There is a minimum income allowance, set at $2,555 / month (eff. 7/1/24 – 6/30/25), which is intended to bring a non-applicant spouse’s monthly income up to this amount. There is also a maximum income allowance, which in 2024, is $3,853.50 / month. While this potentially allows a non-applicant a higher income allowance, the exact amount one can receive is dependent on their shelter and utility costs. However, a Spousal Income Allowance can never push a non-applicant’s total monthly income over $3,853.50. This Monthly Maintenance Needs Allowance is intended to ensure the non-applicant spouse does not become impoverished.
Assets
In 2024, the asset limit is $3,000 for a single applicant. For married couples, the asset limit is slightly higher at $6,000. This hold true for the PCA Program regardless of whether one or both spouses are applicants.
With CFSS, assets will be calculated differently when just one spouse is an applicant. While all assets of a married couple are considered jointly owned, the non-applicant spouse is allocated a larger portion of the assets to prevent spousal impoverishment. In this case, the applicant spouse can retain up to $2,000 in assets and the non-applicant spouse can keep up to $154,140. This larger allocation of assets to the non-applicant spouse is called a Community Spouse Resource Allowance.
Some assets are not counted towards Medicaid’s asset limit. These generally include an applicant’s primary home, household furnishings and appliances, personal effects, and a vehicle.
While there is a 60-month Look-Back Rule in which Medicaid checks past asset transfers of those applying for Nursing Home Medicaid or home and community based services via a Medicaid Waiver, it is not relevant for the Personal Care Assistance Program. The Look-Back Rule will, however, apply to the Community First Services and Supports Program.
Home Ownership
The home is often the highest valued asset a Medicaid applicant owns, and many persons worry that Medicaid will take it. For eligibility purposes, Minnesota Medicaid considers the home exempt (non-countable) in the following circumstances.
– The applicant lives in the home or has “Intent” to Return home, and in 2024, their home equity interest is no greater than $713,000. Home equity is the current value of the home minus any outstanding mortgage. Equity interest is the portion of the home’s equity value that is owned by the applicant.
– A spouse lives in the home.
– The applicant has a minor child (under 21) living in the home.
– The applicant has a blind or disabled child living in the home.
Learn more about the potential of Medicaid taking the home here.
Medical Criteria: Functional Need
While many Medicaid long-term care programs require an applicant to have a Nursing Facility Level of Care (NFLOC) need, this is not required for the Personal Care Assistant Program, nor will it be required for Community First Services and Supports. For PCA / CFSS, an applicant must need only require assistance with one Activity of Daily Living (ADL) or exhibit a qualifying behavior. ADLs are essential for day-to-day functioning, and for PCA / CFSS, these include mobility, transferring, positioning, eating, toileting, bathing, grooming, and dressing. A qualifying behavior is one that puts oneself, another person, or property in danger. Relevant to persons with Alzheimer’s disease or a related dementia, this might include wandering. However a diagnosis of Alzheimer’s disease does not mean one will automatically meet the level of care need.
Qualifying When Over the Limits
Having income and / or assets over Medicaid’s limit(s) does not mean an applicant cannot still qualify for MN Medicaid / Medical Assistance. There are a variety of planning strategies that can be used to help persons who would otherwise be ineligible to become eligible. Some of these strategies are fairly easy to implement, and others, exceedingly complex. Below are the most common.
Minnesota has a Medically Needy Spend-Down Program for applicants who have high medical expenses relative to their income. Via this program, applicants are permitted to spend “excess” income on medical expenses and health care premiums, such as Medicare Part B, in order to meet Medicaid’s Medically Needy Income Limit.
When persons have assets over the limits, they can “spend down” excess assets on ones that are exempt (not counted). Examples include paying off debt, making home improvements, such as updating heating and plumbing, and purchasing pre-paid funeral and burial expense trusts called Irrevocable Funeral Trusts. A Medicaid-Compliant Annuity, which takes a lump sum of assets and converts them into an income stream, also can lower countable assets. There are many other options when the applicant has assets exceeding the limit.
Inadequate planning or improperly implementing a Medicaid planning strategy can result in a denial or delay of MN Medicaid benefits. Professional Medicaid Planners are educated in the planning strategies available in Minnesota to meet Medicaid’s financial eligibility criteria without jeopardizing Medicaid eligibility. While Medicaid’s 60-month Look-Back Rule does not apply to the PCA Program, it does apply to Nursing Home Medicaid and other long-term care Medicaid programs (i.e., Minnesota’s Elderly Waiver). At this time, it is also thought it will apply to CFSS. Furthermore, as more extensive Medicaid-funded care might be required in the future, it is vital that one not violate the Look-Back Rule. Medicaid Planning strategies should ideally only be implemented with careful planning and well in advance of the need for long-term care. However, there are some workarounds, and Medicaid Planners are aware of them. For these reasons, it is highly suggested one consult a Medicaid Planner for assistance in qualifying for Medicaid / Medical Assistance when over the income and / or asset limit(s). Find a Medicaid Planner.
How to Apply for Minnesota Medicaid PCA / CFSS Programs
Before You Apply
Prior to submitting an application for PCA / CFSS, applicants need to ensure they meet the Minnesota Medicaid / Medical Assistance eligibility criteria. Applying when over the income and / or asset limit(s) will be cause for denial of benefits. The American Council on Aging offers a free Medicaid Eligibility Test to determine if one might meet Medicaid’s eligibility criteria. Take the Medicaid Eligibility Test.
As part of the application process, applicants will need to gather documentation for submission. Examples include copies of Social Security and Medicare cards, previous bank statements, proof of income, copies of life insurance policies, property deeds, and pre-need burial contracts. Unfortunately, a common reason applications are held up is required documentation is missing or not submitted in a timely manner.
Application Process
To apply for the Personal Care Assistance Program, which will become the Community First Services and Supports Program beginning October 1, 2024, seniors should contact their local county or tribal office to request an assessment. Seniors who already receive MN Medicaid / Medical Assistance and are enrolled in Minnesota Senior Health Options (MSHO) or Minnesota Senior Care Plus (MSC+) should contact their Managed Care Organization / Health Plan. Click here for contact information by health plan.
Learn more about the Personal Care Assistance Program here. Learn more about the Community First Services and Supports Program and to learn more about the similarities and differences between the PCA and CFSS Programs here. A video that goes into detail about both programs can be found here.
The Minnesota Department of Human Services (DHS) administers the Personal Care Assistance Program and will administer the Community First Services and Supports Program.
Approval Process & Timing
The Medicaid application process can take up to 3 months, or even longer, from the beginning of the application process through the receipt of the determination letter indicating approval or denial. Generally, it takes one several weeks to complete the application and gather all of the supportive documentation. If the application is not properly completed, or required documentation is missing, the application process will be delayed. Based on federal law, Medicaid offices have up to 45 days to review and approve or deny one’s application (up to 90 days for disability applications). Despite the law, applications are sometimes delayed even further.