What Kansas non-medical caregivers can do: the 16 assigned duties

Four rules work together:

1. The policy. "Each licensee shall include the following requirements in written policies and procedures for use by a supportive care worker", and the 16 areas follow (K.A.R. 28-51-117(g)). KDHE asks for "A Policy for Assigned Duties" in its Provision of Services folder.
2. The scope of practice. "Each licensee providing supportive care services shall have written policies and procedures describing the appropriate scope of practice for a supportive care worker", consistent with the statute, the rule and the training each worker needs (K.A.R. 28-51-117(b)).
3. The written assignment. "Written assignments and instructions for supportive care workers shall be prepared by a manager based on the plan of care." It sets the procedures, when to report to the supervisor, and documenting each visit (K.A.R. 28-51-117(f)).
4. Only what you applied for. "Each home health agency shall offer only the home health services, HCBS, or supportive care services specified on the home health agency’s initial application or renewal application." (K.A.R. 28-51-101(d)(2))

Every applicant also attests that "the provision of any services that are not within the scope of the HHA level of licensure obtained, are grounds for but not limited to, termination or loss of all or any HHA State License" (Attestation Form, p. 1). And KDHE says supportive care workers "are not able to work as Home Health Aides or Certified Nursing Assistants due to no nursing services under the Non-Medical Supportive Care Services license" (Letter of Introduction, Option 2). A CNA can work for you, but only within these 16 areas (Attestation Form, p. 2).

A worker may help with medication "only if the medications have been preselected by the client, a family member, a nurse, or a pharmacist and are stored in containers other than the prescription bottles", and each reminder container must be clearly marked with the day and time of the dose (K.A.R. 28-51-117(g)(1)(A)). The help is limited to four things:

1. asking whether the medications were taken;
2. verbal prompting to take them;
3. handing the marked reminder container to the client; and
4. opening the marked container if the client is physically unable to.

• All medications. The limits apply to prescription and nonprescription medications alike ((g)(1)(B)).
• No administration. "Supportive care workers and other employees of a home health agency providing supportive care services shall not participate in medication administration." ((g)(1)(B)) The rules define it as "the provision of assistance to a patient in the ingestion, application, or inhalation of a medication", following the directions of a physician, nurse practitioner, clinical nurse specialist or physician assistant (K.A.R. 28-51-100(bb)).
• No set-up. Your policies must indicate "medications shall not be set up by supportive care workers" (K.A.R. 28-51-104(c)(3)(H)). The rules define setting up as "to arrange medication for later medication administration according to instructions from a pharmacy, the individual prescribing the medication, or a licensed nurse" (K.A.R. 28-51-100(ww)) So, by our reading, caregivers do not fill pill organizers.
• Report errors. "Each supportive care worker shall report immediately to the manager whenever medications are taken too often, not taken often enough, or not taken at the correct time" as marked in the container ((g)(1)(B)).
• No applying medication. "A supportive care worker shall not apply medication." ((g)(2)) KDHE told providers: "Assisting a patient in holding folds while the patient applies medication is acceptable." (KDHE Questions and Feedback, p. 36)
• No insulin prefilling. "No unlicensed person employed by a home health agency, in the course of employment with a home health agency, shall prefill insulin syringes for any patient served by the home health agency." It is a class C misdemeanor (K.S.A. 65-5116(b)-(c)).

CareRulebook’s manual puts these in Policy 4.8, with a medication reminder log that records any dose problem reported to the manager, and the insulin rule in Policy 4.9.

Paragraph (g)(14) is the longest of the 16, and the one agencies ask about most:

• Who can be helped. A worker may help with transfers, as the written assignment provides, if the client has sufficient balance and strength to stand and pivot and assist with the transfer (K.A.R. 28-51-117(g)(14)).
• The hard limit. "A supportive care worker shall not perform assistance with a transfer if the client is unable to assist with the transfer." ((g)(14))
• Family transfers. "Any supportive care worker may assist a family member with transferring the client." ((g)(14))
• Adaptive and safety equipment, such as wheelchairs, tub seats and grab bars: "if the client and the supportive care worker are fully trained in the use of the equipment and the client, client’s family member, or guardian can direct the transfer step-by-step" ((g)(14)).
• Gait belts. "A gait belt may be used in a transfer as a safety device for the supportive care worker if the supportive care worker has been properly trained in the use of a gait belt." ((g)(14))
• Lift devices. "Any supportive care worker with training and demonstrated competency may assist a client in a transfer involving a lift device." ((g)(14))

A Hoyer lift for a client who cannot bear weight? The rule allows lift transfers in one sentence and forbids any transfer for a client unable to assist in another. By our reading, a lift transfer is allowed only for a client who can still assist with it in some way; a client who cannot assist at all is outside supportive care for transfers. KDHE has not answered this in writing, and it is on our list of questions for KDHE.

What KDHE expects of lift training. In April 2026 KDHE said: "KDHE maintains that training is required to use a lift and must be conducted by an individual with knowledge of the device, beyond reading the user manual." It added that training on one lift does not carry over to another (KDHE Questions and Feedback, p. 34). KDHE said this while reviewing its draft, which would remove lift transfers from supportive care.

CareRulebook’s manual lets you choose whether your agency offers lift transfers at all (Policy 4.5); if it does, the lift goes on the written assignment and the worker is trained and checked on the client’s own lift (Policy 2.6). How competency is shown and re-checked every year: Kansas caregiver training.

"Any supportive care worker may assist a client with ambulation who can balance and bear weight if a qualified health professional determines that the client is independent with an assistive device." (K.A.R. 28-51-117(g)(3))

• Who counts. ""Qualified health professional" means a physician, a registered nurse, a physical therapist, an occupational therapist, a respiratory therapist, a speech therapist, a dietitian, or a social worker." (K.A.R. 28-51-100(ss))
• What "independent" means. KDHE: "As the current regulation is worded, the client must be "independent with an assistive device," meaning that they do not need assistance with the assistive device." (KDHE Questions and Feedback, p. 33)
• Reminders are fine. KDHE: "If a client is independent with the use of an assistive device, a supportive care service agency may cue the client to use the device." (p. 45)

The catch. A supportive care agency may not use nursing of any kind (Attestation Form, p. 2), so it has no professional of its own to make the finding. KDHE itself said that because a qualified "health professional is considered a provider of skilled services, the inclusion of this requirement in a supportive care service agency is not appropriate", which is why its draft rewords the rule (p. 45). Until the rule changes, the current text still applies.

By our reading, the finding comes from the client’s own physician, physical therapist or other qualified health professional, in writing, and is kept in the client record before walking help goes on the assignment. The rules do not say what form the finding takes, or whether it is needed for a client who walks without any device. Both are open questions for KDHE.

"Any supportive care worker may assist a client with nail care, including soaking nails, pushing back cuticles without utensils, and filing nails." But "nail trimming for clients shall be performed only by a supportive care worker of a home health agency that indicated in the home health agency’s initial application or renewal application that it intends to provide home health services." (K.A.R. 28-51-117(g)(10)) A supportive-care-only agency has not applied to provide home health services, so by our reading its workers do not trim nails, including toenails. Clients who need trimming can be referred to a podiatrist or a skilled agency.

What the Skilled Services license involves. KDHE says it "encompasses all home health services allowable by law in Kansas" (KDHE Skilled Services page). In return, for each patient the agency needs an order from the patient’s physician, nurse practitioner, clinical nurse specialist or physician assistant (K.A.R. 28-51-104(c)(1)(A)) and a registered nurse available or on call during all hours home health services are provided ((c)(1)(J)). Its home health aides must be Kansas-certified nurse aides who complete a 20-hour home health aide course (K.A.R. 28-51-113(a)). KDHE’s fees are higher too: Skilled Services or HCBS: $500 initial (under 100) or $750 (100 or more); renewal $350 or $600. (K.A.R. 28-51-101; KDHE fees).

The same license is needed for Medicaid HCBS waiver work (Letter of Introduction) and, KDHE warns, for many payers including Veterans Affairs (Option 2). Which license fits your plans: Kansas home health vs home care.

The 16 areas are all hands-on help. KDHE’s letter says the license also covers "chore and/or companionship services as well as Activities of Daily Living (ADLs)" (Letter of Introduction, Option 2), and the rules set no limits on housekeeping, errands or company.

Whether a business that offers only those, with no hands-on help, needs a license at all is not settled. KDHE told providers in April 2026 that such tasks "do not require hands-on care and many of these are available by businesses (cleaning agencies, grocery store delivery services, ride share companies, etc.) not required to be licensed as a home health agency." (KDHE Questions and Feedback, p. 36). Its 2024 letter says every agency needs a license. Our reading and the full picture: who needs a Kansas license.