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Indiana · Home health vs home care · IC 16-27-4 and IC 16-27-1
Indiana has two IDOH licenses for agencies that work in people’s homes: a personal services agency (PSA) for non-medical care, and a home health agency for nursing and therapy. Each costs $250 a year in IDOH fees. Here is what each allows, where a PSA has to stop, how Medicaid waiver work and the August 2026 pause fit in, and what CMS’s 2026 moratorium does and does not touch.
Quick answer
What most people call home care is, in Indiana, a personal services agency (PSA): attendant care, homemaker and companion services at the client’s home, with no nursing. A home health agency is one that provides or offers to provide nursing services, or nursing services and at least one other home health service such as therapy or home health aide services, for pay. IC 16-27-1-2(a) IDOH issues both, each for one year with a $250 IDOH fee, and the two run under different laws: IC 16-27-4 for a PSA, IC 16-27-1 and 410 IAC 17 for home health.
A PSA has firm limits. Services that need a health care professional’s order are not personal services, a PSA may not manage a client’s medical condition, and IDOH’s 2022 instruction letter says it may not use "health" or "nursing" in its name. IC 16-27-4-4(b)(4) IDOH letter (08.2022)
Two 2026 pauses sit on top. Indiana Medicaid stopped certifying new waiver providers of Attendant Care and Home and Community Assistance from August 1, 2026, and CMS halted Medicare enrollment of new home health agencies nationwide from May 13, 2026, which is federal enrollment, not IDOH’s license. Neither notice mentions the IDOH PSA license (our reading of BT2026124 and QSO-26-11).
Each line below is from the statute, IDOH’s rules or an official notice, linked in the cell.
| Personal services agency (home care) | Home health agency | |
|---|---|---|
| What it covers | Attendant care, homemaker services and companion services, provided at the client’s residence. IC 16-27-4-4(a) | Nursing services, or nursing services plus at least one other home health service such as therapy, medical social services or home health aide services. IC 16-27-1-2, -5(b) |
| Orders and plans | Services that need a health care professional’s order are outside personal services. The manager or a designee writes a service plan, which the client signs. IC 16-27-4-4(b)(4), -10 | Care follows a written medical plan of care established and periodically reviewed by the physician, dentist, chiropractor, optometrist or podiatrist. 410 IAC 17-13-1(a) |
| Who leads | A manager the agency employs. The statute sets no qualifications for the role and has no nurse role. IC 16-27-4-9(a) | A qualified administrator, and a physician or a registered nurse with two years of nursing experience, with at least one year of supervisory or administrative experience, directing nursing and other therapeutic services. 410 IAC 17-9-2, 17-12-1(d) |
| The rules | The statute itself. IDOH may adopt only procedural rules and may not add to the requirements; the TB test is borrowed from the home health rule. IC 16-27-4-20(b) | IC 16-27-1 plus IDOH’s rules in 410 IAC 17, which IDOH has proposed to readopt without changes. LSA #25-758 |
| IDOH fee and term | $250 with each application; the license lasts one year. IC 16-27-4-6(d), (h) | $250, nonrefundable; the license lasts one year. 410 IAC 17-10-1(c), (n) |
| Getting the license | IDOH issues the license on a completed application showing prima facie compliance, with the fee. IDOH’s form says the documents are approved first. IC 16-27-4-6(e) | IDOH may issue a 90-day provisional license pending an on-site inspection, then a full license if the agency complies. 410 IAC 17-10-1(e)-(g) |
| Inspections | IDOH may inspect at initial licensing or renewal; the client rights statement says IDOH does not inspect PSAs as part of licensing but investigates complaints. IC 16-27-4-6(e), -12(12) | IDOH says it inspects state-licensed home health agencies, and monitors agencies on behalf of CMS. IDOH home health page |
| Branch offices | Within a 120-mile radius of the parent agency. IC 16-27-4-6(b) | Within 120 minutes’ driving time of the parent agency. 410 IAC 17-9-5 |
| Civil penalty | Up to $1,000. IC 16-27-4-19 | Up to $10,000. IC 16-27-1-12 |
| Medicaid waiver attendant care | FSSA marks the PSA license "Required" for Attendant Care and Home and Community Assistance. Provisional licenses are not accepted. OMPP document definitions | FSSA lists a home health agency license as the alternative ("Optional"). Provisional licenses are not accepted. OMPP document definitions |
| Medicare | CMS’s 2026 moratorium memo covers home health agencies and hospices. It does not mention personal services agencies. QSO-26-11 | Enrollment of new home health agencies halted nationwide from May 13, 2026. QSO-26-11 |
Fees are IDOH’s, paid to the state, and separate from any CareRulebook price. The home health application is State Form 4008, with separate groups of forms for a state license (including one seeking Medicaid) and for Medicare. IDOH home health page (updated September 28, 2026)
A PSA’s attendant care is broad: bathing, toileting, dressing, feeding, transfers including lift equipment, and help with medications such as reminders, opening preset containers and help taking them. IC 16-18-2-28.5 The Indiana start-up guide sets out each task. The home health chapter leaves that work alone. It says "This chapter does not prohibit the provision of" homemaker services, companion services, help with cognitive tasks such as managing finances, or attendant care services. IC 16-27-1-10
Four things draw the line on the other side:
Medicaid draws its own line. FSSA’s Attendant Care definition says waiver attendant care "cannot provide care for skilled needs such as specialized feedings, Hoyer lift, wound care, or ostomy care." FSSA Attendant Care service definition That is narrower than the PSA license, which allows lift services.
A licensed home health agency does not need a PSA license, but a personal services operation run within it must meet IC 16-27-4. IDOH asks for a letter with the license number, the request and the start date, an attendant care job description and an updated training and evaluation policy with a passing score, and the agency "may not offer additional services until it has received approval".
A home health agency’s personal services operation follows IC 16-27-4, and IC 16-27-4 does not apply to its home health operations. So the personal services side needs the IC 16-27-4 service plans, satisfaction reviews, client rights statement and competency checks, even inside a home health agency.
The statute expects that one person may hold both licenses: where they do, the PSA renewal inspection is, as far as feasible, held at the same time as the home health inspection.
A PSA that wants to add nursing cannot do it under its PSA license, by our reading: nursing services for pay are what define a home health agency, which needs its own license (State Form 4008 and IDOH’s $250 fee). IC 16-27-1-2 IDOH home health page
A decision aid we built from the definitions and notices cited in each row. It is our reading, not IDOH’s and not legal advice. If a service sits near the line, email IDOH’s PSA program at PSA@health.IN.gov before you apply. IDOH PSA program page
| If you plan to offer | The license that matches | IDOH fee | Source |
|---|---|---|---|
| Companionship, housekeeping, laundry, shopping, meals, errands and escort, for pay | Personal services agency | $250 a year | IC 16-27-4-4(a) |
| Hands-on help with bathing, toileting, dressing, feeding and transfers (including lifts), and help with medications such as reminders and opening preset containers | Personal services agency | $250 a year | IC 16-18-2-28.5IC 16-18-2-28.5(b)(3) |
| Nursing treatment and procedures, physical, occupational or speech therapy, medical social services or home health aide services, or anything that needs a health care professional’s order | Home health agency | $250 a year | IC 16-27-1-2, -5IC 16-27-4-4(b)(4) |
| Both non-medical care and nursing | A home health agency license, with personal services added once IDOH approves (no separate PSA license needed); the personal services side follows IC 16-27-4 | $250 a year | IC 16-27-4-6(j)IDOH home health page |
| Caring for Medicaid waiver clients (Attendant Care, Home and Community Assistance) | A full PSA or home health license, then OMPP certification and IHCP enrollment, which are paused for new providers from August 1, 2026 | IDOH fee for the license | OMPP document definitionsBT2026124 |
| Billing Medicare for home health | Home health agency, then Medicare enrollment, which is halted for new agencies from May 13, 2026 | $250 a year (IDOH) | IDOH home health pageQSO-26-11 |
| Working on your own for family only, or for no more than 3 people per home and 7 at a time | Not a personal services agency | None | IC 16-27-4-5(b)(1) |
The license check on the Indiana guide asks what your business will do and who pays, and points you to the right license.
Indiana Medicaid · In force from August 1, 2026
For Attendant Care and Home and Community Assistance under the Medicaid waivers, FSSA’s document list says the provider "Must have one of the following": a PSA license, marked "Required", or a home health agency license, marked "Optional", and "Provisional licenses will not be accepted". OMPP Required Document Definitions (updated August 25, 2025) By our reading, a new home health agency’s 90-day provisional license would not count until IDOH issues the full one. 410 IAC 17-10-1(e)
Waiver attendant care is non-skilled: direct, hands-on help with activities of daily living. Skilled needs require an RN, LPN or other health professional. FSSA Attendant Care service definition After the license come three steps: OMPP certification, IHCP enrollment and waiver program enrollment. FSSA, Medicaid HCBS Certification
What the bulletin does not say: it does not mention the IDOH PSA license, private-pay clients or home health agency services. By our reading, IDOH licensing and private-pay work carry on, and the pause decides only when you can add Medicaid waiver clients.
National · In force from May 13, 2026
IDOH’s home health page lists a separate set of forms "FOR MEDICARE", including the CMS-855A enrollment application. IDOH home health page For new agencies, that step is paused: "Effective May 13, 2026, CMS will halt the enrollment of new Hospice and HHA providers or HHA branch or practice locations." CMS, QSO-26-11
What it does not do, by our reading: QSO-26-11 is about enrollment. It says nothing about state licensing, so it does not stop IDOH licensing a home health agency, and it does not mention personal services agencies, which provide non-medical services and are not home health agencies.
Its instructions speak of Medicare enrollment applications. Its background adds that CMS announced the moratoria under its authority to fight fraud, waste and abuse in Medicare, Medicaid and CHIP, without saying how that applies to enrollment with Indiana Medicaid. If you plan to bill Indiana Medicaid for home health, check with Indiana Health Coverage Programs (the IHCP) before you count on it. QSO-26-11, page 1
CareRulebook
IDOH’s form asks for nine policies and seven forms and says it approves them before it issues the license. CareRulebook writes them for your agency, in IDOH’s order, with the statute quoted under each in the full manual. It covers personal services agencies, not home health agencies.
$199CareRulebook founding price for the first 50 Indiana agencies, then $249. Not an IDOH fee.
It depends. Not the state license: IDOH’s home health page still describes applying for one, with a $250 fee, and the rules let IDOH issue a 90-day provisional license pending an on-site inspection. What is paused is federal enrollment: from May 13, 2026, CMS halted the enrollment of new home health agencies nationwide for six months, which it can extend, with no exceptions for individual providers. A personal services agency license is a different license, and the CMS memo does not mention it.
"Effective May 13, 2026, CMS will halt the enrollment of new Hospice and HHA providers or HHA branch or practice locations."
No. Not according to IDOH. Its 2022 instruction letter says a PSA may not advertise as a home health agency or use the word "health" or "nursing" in its name, pointing to IC 16-27-1-15, which makes operating or advertising an unlicensed home health agency a Class A misdemeanor.
"The personal services agency may not advertise as a home health agency or use the word "HEALTH" or "NURSING" as part of the agency’s name."
No. Not by its terms. Bulletin BT2026124 pauses certification and enrollment for listed Medicaid waiver services, and changes of ownership, added counties and added services for existing waiver agencies. It does not mention the IDOH PSA license or private-pay clients, so by our reading IDOH licensing and private-pay work carry on. New Medicaid waiver work waits until the pause ends, unless the IHCP grants an exception.
"The moratorium will prevent certification and enrollment for certain waiver services as well as changes of ownership, adding counties and adding services subject to the moratorium for existing HCBS agencies."
No. The agency must employ a manager responsible for organization and daily operation, but IC 16-27-4 sets no license, degree or experience for the manager and no nurse role. A PSA may not manage medical conditions; nursing needs a home health agency license.
"The manager is responsible for the organization and daily operation of the personal services agency."
Indiana calls non-medical home care "personal services": attendant care (hands-on help such as bathing, dressing, toileting, transfers and help with medications), homemaker services and companion services, provided at the client’s home. An agency providing them needs a personal services agency (PSA) license under IC 16-27-4. A home health agency provides nursing services, or nursing plus another home health service such as therapy or home health aide services, under IC 16-27-1 and IDOH’s rules in 410 IAC 17. IDOH issues both licenses, and each costs $250 a year.
The statute ties the scope to the license, not to the worker. Services that need a health care professional’s order to be lawfully performed are not personal services, a PSA may not manage a client’s medical condition, and IDOH’s 2022 instruction letter says a PSA may not provide medical care. IC 16-27-4 does not say whether a licensed nurse employed by a PSA may do nursing tasks. By our reading, an agency that provides or offers nursing services for pay falls within the definition of a home health agency and needs that license. Ask IDOH if your plan sits near the line.
IDOH charges $250 with each PSA application (initial, renewal or change of ownership) under IC 16-27-4-6(d), and a nonrefundable $250 with a home health agency application under 410 IAC 17-10-1(c). Both licenses last one year. These are IDOH’s fees, not CareRulebook prices.
You can apply to IDOH for a home health agency license; the CMS memo does not mention state licensing. Medicare is the obstacle: CMS halted the enrollment of new home health agencies nationwide from May 13, 2026, for six months, which it can extend, with no exceptions for individual providers. Initial enrollment applications submitted during the moratorium are denied and must be resubmitted once it is lifted, and accreditation does not get around it.
Yes. A licensed home health agency does not need a PSA license; it asks IDOH to add personal services to its license and may not offer them until IDOH approves. Its personal services operation follows IC 16-27-4, and IC 16-27-4 does not apply to its home health operations. The statute also provides for a person who holds both a PSA license and a home health license: IDOH holds the two renewal inspections together where feasible.
Not by its terms. Bulletin BT2026124 pauses Medicaid waiver certification and enrollment for listed services, including Attendant Care and Home and Community Assistance, from August 1, 2026. It does not mention the IDOH license or private-pay clients, so by our reading you can still be licensed by IDOH and serve private-pay clients. By our arithmetic the first six months end around February 1, 2027, unless the IHCP extends the pause.
Neither IC 16-27-1 nor 410 IAC 17 mentions a certificate of need, and IDOH’s home health application page does not list one. We have not checked other Indiana law for it, so if your plan depends on the answer, ask IDOH’s home health program before you commit.
Not according to IDOH. Its 2022 instruction letter says a PSA may not advertise as a home health agency or use the word "health" or "nursing" in its name, pointing to IC 16-27-1-15, which makes operating or advertising an unlicensed home health agency a Class A misdemeanor.
We watch IC 16-27-4, IDOH’s home health rules (proposed for readoption), the Indiana Medicaid waiver pause and the CMS home health moratorium. Leave your email and we will tell you when an Indiana rule changes, or when either pause is extended or lifted.
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Indiana
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Manual
Indiana policy manual
The policies and forms IDOH asks for, written for your agency.
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