Indiana personal services agency (PSA) license for non-medical home care

One license covers personal care, homemaking and companionship

Many states split non-medical home care into tiers, with a light registration for companion-only agencies and a stricter license for hands-on care. Indiana does not. IC 16-27-4-4 defines “personal services” as three things, all provided at the client’s residence ⁠¹:

• Attendant care services. These are the hands-on tasks. The statute expects each worker to be evaluated on every attendant care task you assign them ⁠¹.
• Homemaker services. Help with or performance of household tasks, “including housekeeping, shopping, laundry, meal planning and preparation, and cleaning” ⁠¹.
• Companion services. Services “that provide fellowship, care, and protection for a client, including transportation, letter writing, mail reading, and escort services” ⁠¹.

A personal services agency is “a person that provides or offers to provide a personal service for compensation, whether through the agency’s own employees or by arrangement with another person” ⁠¹. The words “or by arrangement” matter: a referral or matching model that places independent caregivers still falls within the definition. So does merely offering the service, so advertising before you are licensed is a risk. The statute says a PSA may not be “opened, operated, managed, or maintained or conduct business without a license” ⁠¹.

IDOH’s program page calls this the “Personal Care Services Agency” licensing program, while the statute and the application forms say “personal services agency.” They are the same license ⁠¹⁠².

Where the PSA license stops: medical care and the home health license

The PSA definition excludes “services that require the order of a health care professional for the services to be lawfully performed in Indiana” ⁠¹. Skilled nursing, therapy and other ordered care belong to a home health agency licensed under IC 16-27-1. That route is covered in the Indiana home health agency license guide.

The line also shows up in your paperwork. Every PSA must give clients a rights statement saying “it is not within the scope of the personal services agency’s license to manage the medical and health conditions of the client if a condition becomes unstable or unpredictable” ⁠¹. Under IC 16-27-4-8, if you learn that a client’s condition has become unstable, you must tell the client, their personal representative, a family member or another person the client named that a medical referral is needed, and document that notice in the client record. You may keep providing personal services, but you “may not manage or represent itself as able to manage the client’s medical or health condition” ⁠¹.

Indiana lets one company hold both licenses. A home health agency licensed under IC 16-27-1 that runs personal services “is not required to obtain a license under this chapter,” but its personal services operation “is subject to the requirements of this chapter,” and the home health rules do not apply to that side of the business ⁠¹. If you hold both licenses separately, IDOH will combine the PSA renewal inspection with the home health inspection “to the extent feasible” ⁠¹.

Who is exempt

IC 16-27-4-5(b) and 16-27-4-4(b) exclude the following ⁠¹:

• An individual caregiver with a small caseload. “An individual who provides personal services only to the individual’s family or to not more than three (3) individuals per residence and not more than a total of seven (7) individuals concurrently.” Family means spouse, child, parent, parent-in-law, grandparent, grandchild, brother, brother-in-law, sister, sister-in-law, aunt, aunt-in-law, uncle, uncle-in-law, niece and nephew. The exemption is written for an “individual,” so it does not cover a company that employs caregivers.
• Local health departments under IC 16-20 or IC 16-22-8.
• Supported living providers approved by the Division of Disability and Rehabilitative Services that serve only people with developmental disabilities in placements authorized under IC 12-11-2.1.
• Services outside the definition: incidental services a licensed health facility gives its own patients; services employers or membership organizations give their employees or members when that is not their main business; services a personal services attendant may perform under IC 12-10-17.1; assisted living Medicaid waiver services; and services performed by a facility described in IC 12-10-15.

If you plan to serve residents of a licensed facility, the facility’s own care falls under its license. For that model, see the Indiana residential care facility license guide.

Before you file: entity, office, managers

Secretary of State and IRS papers. State Form 53391 requires the official Indiana Secretary of State document for your entity: articles and certificate of incorporation or organization, a limited partnership registration, or a Certificate of Authority for a foreign corporation. If your trade name differs from the legal name, you also need a Certificate of Assumed Business Name. You must also include the IRS document showing your legal name and EIN, and “the legal name on the IRS and SOS must match” ⁠³.

A physical office and phone. “The applicant must have a physical location and operational telephone for a personal services agency for licensure,” and the agency phone, fax and email must be agency-specific ⁠³. Records must be kept at, or be electronically accessible from, an office in Indiana for at least seven years ⁠¹.

Out-of-state companies. An agency based in another state must be authorized by the Indiana Secretary of State and must have a branch office in Indiana ⁠¹.

A manager and at least one alternate. IC 16-27-4-9 requires you to employ a manager “responsible for the organization and daily operation” of the agency. The manager may delegate duties in writing, and the manager or a designee must be available to take client calls 24 hours a day ⁠¹. Form 53391 asks for a manager and an alternate manager, plus an optional second alternate ⁠³. The statute sets no education or licensure requirement for the manager. Instead, you submit a job description of the manager’s day-to-day duties ⁠³.

Owners. You list every person or organization with direct or indirect ownership or controlling interest of 5% or more, plus every officer, director, partner, member and managing employee. For an LLC, that includes the people behind each member entity ⁠³.

Criminal history checks for owners, managers and staff

At application. Owners, the manager and the alternate managers each need a lifetime expanded or lifetime national criminal history report dated within the past three months ⁠³⁠⁵. An expanded check under IC 20-26-2-1.5 has to verify identity and search every name used, every Indiana county where the person lived, county records in any other state where they lived, federal district courts, sex offender registries, and a multistate criminal database ⁠¹. If you use the Indiana State Police route for a national check, IDOH says to register with the FBI before mailing the fingerprint card, and to have the results sent back to you so you can attach them to your application. Once licensed, you email a copy of the license to the State Police to be added to its inkless fingerprinting system ⁠⁵.

Owner disqualifications. IDOH’s letter for applicants cites IC 16-27-2-3. Under that section as IDOH published it, a person convicted of rape, criminal deviate conduct, exploitation of an endangered adult, or failure to report battery, neglect or exploitation of an endangered adult may not operate a PSA, and neither may a person convicted of theft less than 10 years before applying. Doing so knowingly or intentionally is a Class A misdemeanor ⁠⁵⁠⁶. Both IDOH letters predate House Enrolled Act 1457, which IDOH describes as changing the crimes barring employment ⁠⁸, and the sources I could open do not show whether the owner list in IC 16-27-2-3 changed too. Before you sign the application, ask IDOH ([email protected]) which convictions currently bar an owner or manager, and whether any exception applies to people already operating an agency.

Caregivers. You must apply for each in-home worker’s national or expanded check within three business days after they start providing services in a client’s home. You cannot keep them in client homes for more than 21 calendar days without receiving the result, unless the State Police, the FBI or the private vendor caused the delay ⁠⁶⁠⁷.

Crimes that bar employment since July 1, 2025. House Enrolled Act 1457 expanded the list, effective July 1, 2025 ⁠⁸. IDOH’s May 2025 reference guide to IC 16-27-2-5 lists the following ⁠⁷:

IDOH’s summary of the act adds two points. A PSA must report to IDOH any conviction that bars employment for an aide or other unlicensed person who applies to work for it. And an aide hired before July 1, 2025 with a conviction allowed under the old law may stay with the same employer, but becomes subject to the new list after moving to another agency or leaving and returning ⁠⁸.

The nine policy sets IDOH reviews before licensing

This part of the application takes the most work. Form 53391 requires the policies and documentation listed in IC 16-27-4, and states that “all documentation must be received and approved prior to issuance of a license.” It also warns: “Do not send a handbook as policies and procedures and/or cut and paste IC 16-27-4 as policies and procedures,” and do not mix in policies written for FSSA Medicaid waiver certification ⁠³.

The statute fixes the content of several of these:

• Service plan. The manager or designee writes it before services begin. It must be dated and signed by its author, list the types and schedule of services, and state the client’s right to suspend, end or add services. The client must sign it within 14 days after services start and within 14 days after any permanent change ⁠¹.
• Satisfaction review. Every 76 to 104 days, in person or by phone, put in writing, signed and dated ⁠¹.
• Client rights statement. This goes to the client within 7 days after services begin and must cover 13 items. These include your charges, your policy for notice of price increases, office hours, after-hours contact procedures, your complaint number, and the IDOH complaint line (1-800-246-8909). It also includes a statement that IDOH “does not inspect personal service agencies as part of the licensing process but does investigate complaints” ⁠¹.
• Training. Before a worker performs an attendant care task for a client without direct agency supervision, you must evaluate their competency on that task, train where needed, and then reevaluate. The agency “has the sole discretion” to judge competency. Each evaluation is documented with a date and the evaluator’s signature ⁠¹. Form 53391 asks how you will set the pass mark and gives “80% on written and demonstration/observation skills test” as an example ⁠³.
• Tuberculosis. PSA workers with direct client contact are tested “in the same manner as required by the state department for licensed home health agency employees” ⁠¹. Under 410 IAC 17-12-1(i), that means a baseline two-step Mantoux skin test (the second step one to three weeks after the first) or a QuantiFERON-TB assay, unless the person had a negative skin test in the previous 12 months. People with a history of TB or a positive result need one chest X-ray. Screening is then annual, and anyone with a positive finding may not work without a physician’s approval ⁠⁹. Since December 1, 2019, IDOH has let home health agencies replace these steps with a nationally recognized TB control standard ⁠¹⁰. That advisory is addressed to home health agencies, and neither it nor policy PSA-1 says whether a PSA may use the same alternative. Until IDOH confirms, write your TB policy to 410 IAC 17-12-1 as Form 53391 instructs, and ask IDOH in writing before adopting a different standard.

IDOH policy PSA-1 notes that “certain policies and procedures are not evaluated at the time of initial licensure,” but the agency must still have them in place ⁠¹.

Lift services. If your workers operate patient lifts, IC 16-27-4-6(l), added in 2021, requires a liability insurance policy that covers lift services. Each worker must be trained on general lift standards and then trained at the client’s home on that client’s lift, following the manufacturer’s manual. Clients may decline lift use ⁠¹.

Filing through the IDOH Gateway

1. Get Gateway access

   Sign in through Access Indiana, request access to the IDOH Gateway, and choose “Personal Service Agency.” An IDOH administrator approves the request, and the approval email gives you a registration ID ⁠².

2. Register the agency

   Open “Personal Service Agency License Registration” and click “Register New Agency.” Every field is mandatory, including agency hours. The Details page then shows the payment amount and the license effective date ⁠².

3. Ownership, manager and locations

   Complete these screens. If you will open branches, use “Add Location” ⁠².

4. Upload documents

   Upload the Secretary of State and IRS documents, the criminal history reports, and the nine policy sets listed above ⁠²⁠³.

5. Attest and pay

   Complete the attestation, pay online, and keep the confirmation email ⁠². On the paper form, an owner or CEO and the manager each certify that the owners “are of reputable and responsible character” and that the agency’s policies will not discriminate based on race, color, creed or national origin ⁠³.

6. IDOH review

   Once a completed application shows “prima facie compliance” and the fee is paid, IDOH “shall issue a license.” It may conduct an onsite inspection with an initial license or a renewal ⁠¹. The sources reviewed state no processing time.

State Form 53391, still linked from the program page, is dated September 2018 and gives a mailing address for the IDOH cashier. The program page now directs initial applications and payment to the Gateway ⁠²⁠³. If you are unsure which to use, the division’s contact address is [email protected] ⁠².

Fee, term and branch offices

To add or move a branch, a manager, owner or other designated person on file with IDOH submits the full branch address and a map showing it is within 120 miles ⁠¹. A branch farther away needs its own parent license, because “each parent personal services agency must obtain a separate license” ⁠¹.

Inspections, complaints and enforcement

IDOH may inspect when it reviews an initial license, a renewal or a complaint. The inspection is limited to compliance with IC 16-27-4, or to whether the agency is “permitting or aiding an illegal act” ⁠¹. When a surveyor asks for documents, you must produce them within 24 hours ⁠¹. You must also investigate client complaints yourself, covering both services provided or not provided and lack of respect for the client’s property, and document each complaint and its resolution ⁠¹.

The state health commissioner may issue a probationary license, order a resurvey, deny renewal, revoke the license, or impose a civil penalty of up to $1,000. You can request review of those actions under IC 4-21.5 ⁠¹. IDOH refers unlicensed operations to the attorney general, who may seek an injunction in the county where the agency is located and prosecute violations ⁠¹.

Renewal and changes during the year

The renewal option opens in the Gateway 60 days before the license expires ⁠². The 2018 paper renewal form asks for the application, documents and fee within 15 days before expiration ⁠⁴. The 2018 paper renewal form warns that if the renewal, documents and fee are not received and approved by the expiration date, “the agency may be subject to a civil penalty.” It also says stock transfers, ownership changes, branch changes and name changes cannot be bundled with a renewal ⁠⁴.

Report changes as they happen ⁠⁴:

• Ownership and management. Disclose these at licensure, at each survey, and whenever management changes or more than 5% of the ownership changes hands. Ownership percentages are measured under 42 CFR 420.201 and 420.202 ⁠¹. A stock transfer filing lists who is transferring, who is receiving, the percentage and the effective date, plus a background check on anyone who will hold more than 5% ⁠¹.
• Staff, address, name and office hours. Each needs a written notice from a person on file with IDOH. A new manager also needs a criminal history check, and a name change needs the matching Secretary of State certificate ⁠¹.
• Closing or selling. Give IDOH written notice at least 30 days ahead ⁠¹.

Getting paid through Indiana Medicaid waivers

Since July 1, 2024, FSSA’s Office of Medicaid Policy and Planning has certified providers for the Indiana PathWays for Aging waiver (Medicaid members 60 and older who meet nursing facility level of care), the Health & Wellness waiver and the Traumatic Brain Injury waiver ⁠¹¹. To bill, you need OMPP certification, IHCP enrollment, and contracts with one or more PathWays managed care entities. Each location is certified and enrolled separately ⁠¹¹. The module states that for some services you may need a PSA license “prior to applying for waiver provider certification” ⁠¹¹.

The two services closest to a PSA’s work are these ⁠¹¹:

• Attendant Care. Agency providers qualify as a licensed PSA or a licensed home health agency, and must also meet 455 IAC 2 standards, including liability insurance.
• Home and Community Assistance. This service covers instrumental activities of daily living such as cleaning, laundry and kitchen work. Agency providers qualify as a licensed PSA.

The licensing rule for these two services changed twice in 2026. IHCP Bulletin BT202622 announced that from March 25, 2026, only a PSA license would qualify for new enrollments and recertifications ⁠¹². Bulletin BT202666, issued May 7, 2026, rescinded that change. A PSA license or a home health agency license is again accepted for both services ⁠¹³. Because your PSA license renews every year, IHCP requires you to upload each new license before the one on file expires. Unlike some credentials, it is not verified electronically ⁠¹³.

Sources

1. 1
   Indiana Department of Health, Personal Service Agency License Requirements, Policy IDOH-HCBC/PSA-1 (effective March 26, 2024), reproducing IC 16-27-4 Checked 12 Oct 2026 · Back to text ↑
2. 2
   Indiana Department of Health, Personal Care Services Agency (PSA) Licensing Program Checked 12 Oct 2026 · Back to text ↑
3. 3
   Indiana Department of Health, Application for License to Operate a Personal Services Agency, State Form 53391 (R4 / 9-18) Checked 12 Oct 2026 · Back to text ↑
4. 4
   Indiana Department of Health, Renewal Application for License to Operate a Personal Services Agency, State Form 53591 (R3 / 9-18) Checked 12 Oct 2026 · Back to text ↑
5. 5
   Indiana Department of Health, Criminal History Checks State Statutes, IC 16-27-2 and IC 20-26-2-1.5 (personal services agencies, updated 08.2022) Checked 12 Oct 2026 · Back to text ↑
6. 6
   Indiana Department of Health, Criminal History Checks: IC 16-27-2-3, 16-27-2-4, 16-27-2-5 Checked 12 Oct 2026 · Back to text ↑
7. 7
   Indiana Department of Health, Crimes Barring Employment: A reference guide to IC 16-27-2-5 (May 2025) Checked 12 Oct 2026 · Back to text ↑
8. 8
   Indiana Department of Health, Long-Term Care/Aides Training Program Newsletter, June 2025 Checked 12 Oct 2026 · Back to text ↑
9. 9
   Indiana Department of Health, 410 IAC 17, Home Health Agencies (including 410 IAC 17-12-1) Checked 12 Oct 2026 · Back to text ↑
10. 10
    Indiana Department of Health, Program Advisory Letter AC-2019-01-HHA: Tuberculosis Prevention Requirement for Home Health Agencies Checked 12 Oct 2026 · Back to text ↑
11. 11
    Indiana Health Coverage Programs, OMPP HCBS: Indiana PathWays for Aging Waiver provider reference module (version 2.2, published June 15, 2026) Checked 12 Oct 2026 · Back to text ↑
12. 12
    Indiana Health Coverage Programs, IHCP Bulletin BT202622: Licensure requirements updated for enrollment and recertification of certain waiver providers (February 17, 2026) Checked 12 Oct 2026 · Back to text ↑
13. 13
    Indiana Health Coverage Programs, IHCP Bulletin BT202666: IHCP rescinds licensure requirement for certain waiver providers (May 7, 2026) Checked 12 Oct 2026 · Back to text ↑

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