Minnesota comprehensive home care license: nursing, delegation and the road to Medicare
Minnesota has no separate home health agency license. An agency that sends nurses or therapists into homes, manages medications, or has a registered nurse delegate tasks to aides needs the comprehensive level of the Minnesota Department of Health home care license. The temporary license fee is $4,200 (as published on 2026-10-12), and Medicare certification is possible only after the full license is issued.
Contents13 sections
Key takeaways
- Minnesota issues one home care license at two levels. You need the comprehensive level for nursing or therapy visits, medication management, RN delegation to aides, hands-on transfers, treatments, or complex feeding.1
- The temporary comprehensive license costs $4,200, nonrefundable, as published on 2026-10-12. MDH asks for payment only after it judges the application complete.212
- The application names a registered nurse or other licensed health professional. That person must pass a background study before MDH issues the temporary license.1213
- After the temporary license is issued, you have to serve a client and tell MDH within five days. MDH then surveys you within 90 calendar days. If you serve no clients, the temporary license expires without becoming a full license.3
- Only a full comprehensive licensee can seek Medicare certification. CMS stopped enrolling new home health agencies nationwide on May 13, 2026, and Minnesota Medicaid pays for home health agency visits only to Medicare-certified agencies.131619
Quick facts
| Agency | Minnesota Department of Health, Health Regulation Division, Home Care Program (651-201-4200) |
|---|---|
| Law | Minn. Stat. 144A.43 to 144A.4799 |
| Temporary license fee | $4,200 (basic level: $2,100) |
| Renewal fee | $231 to $7,651 a year, based on home care revenue |
| Clinical lead | Named RN or licensed health professional; RN must be an employee for medication management and delegation to count as direct services |
| First survey | Within 90 calendar days of notifying MDH that you are serving clients |
| Medicare | Only after the full license; new enrollment frozen nationwide since May 13, 2026 |
Fees as published in Minn. Stat. 144A.472, subd. 7, checked 2026-10-12. The renewal schedule has applied since July 1, 2020.
One license, two levels: what “comprehensive” adds
Minnesota does not license home health agencies as a separate category. Every paid home care business holds a single Minnesota Department of Health (MDH) home care license, and the applicant chooses between the basic and comprehensive levels.1 The basic level covers assistive tasks only. The comprehensive level covers all basic services plus one or more of the following:1
- services of an advanced practice registered nurse, physician assistant, RN, LPN, physical, occupational or respiratory therapist, speech-language pathologist, dietitian or nutritionist, or social worker
- tasks that an RN delegates to unlicensed staff, or that a licensed health professional assigns to them
- medication management
- hands-on help with transfers and mobility
- treatments and therapies
- feeding help for clients with complicating eating problems, such as difficulty swallowing, recurrent aspiration, or tube, parenteral or IV feeding
- other complex or specialty health care services
Hands-on transfers are the item that most often catches founders. An agency that plans only personal care, but whose aides physically lift clients from bed to wheelchair, is outside the basic level. If that is your model, compare this license with the basic home care license. Before services start, you must give each client a written statement saying which license level you hold and which services you cannot provide under it.5
A temporary licensee that applied at the basic level can move up to comprehensive before its survey by notifying MDH in writing and paying the difference between the two fees. Moving down earns no refund.3
Who does not need it, and when another license fits instead
The statute exempts the following from home care licensure:1
- personal care assistance providers under Medical Assistance
- providers that DHS licenses for semi-independent living services or for developmental disability home and community-based services
- home-management-only providers registered with MDH
- a Minnesota-licensed nurse, therapist, dietitian, social worker or speech-language pathologist who works in clients’ homes independently, without contracting with or being employed by an agency
Exempt providers must still follow the home care bill of rights. Counties and other government units are not exempt and must be licensed.1 Legislation in 2026 added federally qualified health centers to the exemption list when they provide certain nursing services defined in federal law.24
Housing is the hard boundary. A home care licensee may not provide sleeping accommodations along with care. The MDH application tells anyone who plans both to apply for a provisional assisted living license instead.12 If you plan a residence, see the assisted living facility license. If you plan a day program, see the adult day services license.
The RN you name on the application
The comprehensive application has a section for a “Registered Nurse/Other Licensed Health Professional.” It asks for that person’s license number and whether they work for other home care providers, and if so, how many.12 MDH requires all owners, managerial officials and the named RN or licensed health professional to pass background studies before it issues the license.13 The statute itself names owners and managerial officials, and a person disqualified under chapter 245C may not be involved in managing or operating the provider.11 DHS runs those studies.12 Since August 1, 2022, a person licensed by a health-related licensing board who already had a background check under Minn. Stat. 214.075 does not get a separate DHS NETStudy 2.0 study.13
How you employ that nurse matters. On the application you code each service as 1 (provided directly by your employees), 2 (provided by contract with another licensed provider) or 3 (both). MDH counts medication management and delegation to unlicensed staff as direct services only if the RN, or the licensed health professional for non-nursing tasks, is your direct employee.12 You must provide at least one home care service directly, and contracted services do not count toward that.12
After licensure, the RN has ongoing duties under the statute:
- A comprehensive licensee must have an RN available for consultation whenever staff are performing delegated nursing tasks, and an appropriate licensed health professional for delegated therapy tasks. The contact must be reachable in person, by phone or by other means.10
- An RN or appropriate licensed health professional must directly supervise each staff member who performs delegated tasks within 30 days after that person first performs them. Supervision of medication or treatment administration must include watching the staff member give the medication or treatment.10
Sixteen policies before MDH asks for the fee
The managerial official signs a verification that the agency has 16 written policies in place. Ten apply to every home care applicant and cover:12
- reporting maltreatment of minors and vulnerable adults
- background studies
- staff orientation, training and competency evaluation
- complaints
- initial evaluation of client needs
- ongoing client assessments
- the client bill of rights
- infection control
- medication, treatment and exercise reminders
- tuberculosis screening
The other six apply only at the comprehensive level, and Minn. Stat. 144A.472, subd. 2 lists them:2
- initial and ongoing client assessment by an RN or appropriate licensed health professional
- verifying that nurses’ and therapists’ licenses are current
- medication and treatment management
- delegation by RNs and licensed health professionals
- supervision of RNs and licensed health professionals
- supervision of unlicensed staff performing delegated tasks
Medication management policies must be written under the supervision of an RN, licensed health professional or pharmacist. Treatment and therapy policies must be written under an RN or appropriate licensed health professional.67 At every renewal, a comprehensive licensee must verify that these six policies are still current.2
Filing order and MDH’s clock
Set up the entity and service area
The application asks for the legal name exactly as registered with the Minnesota Secretary of State, IRS documentation of your FEIN, every county you intend to serve, and any other Minnesota licenses or enrollments you hold or have pending, such as adult foster care, 245D services, PCA or assisted living.12
Line up coverage
You must attach evidence of workers’ compensation coverage if you have employees, and liability insurance if you carry it. An applicant with no employees can check a box promising to buy workers’ compensation coverage and notify MDH once it hires.12
Upload to the portal
You file the application and attachments in MDH’s Facility and Provider Licensing System. MDH acknowledges receipt there and may reject incomplete applications.12 The form in use on 2026-10-12 is dated 09/16/2025.12
Pay when invoiced
MDH requests the $4,200 only after it decides the application is complete. It considers the application complete only when all documents and background studies are submitted and verified.12 Fees are nonrefundable.2
Wait for the decision
By statute, MDH must issue or deny a temporary license within 90 days after it receives a complete application.3 MDH’s own application FAQ says 60 days once the application is deemed complete,13 so plan on the shorter figure but rely on the statute’s outer limit. The application warns that MDH may also hold an in-person or telephone conference with you during review.12
From temporary license to full license
The temporary license lasts up to one year, and you must meet the full home care law from its first day.3 What happens next depends on clients:
- Within five days of starting services, you must notify MDH that you are serving clients. Failing to notify carries a $1,000 fine.32
- MDH must survey you within 90 calendar days after it learns you are providing services.3 The initial full survey must happen within 14 months of the temporary license.4
- If you report your first clients within 45 days before the temporary license expires, MDH may extend it by up to 60 days so it has time to survey.3
At the comprehensive level, the survey covers everything checked at the basic level plus three areas: delegation to unlicensed staff; client assessment, monitoring and reassessment; and medication, treatment and therapy management.4 If you are in substantial compliance, MDH issues the full comprehensive license. If not, MDH either terminates the temporary license or extends it for up to 90 days with conditions, and you can ask for an internal reconsideration.3
After that, MDH surveys at least once every three years.4 Fines are imposed immediately, with no chance to correct first: $500 per violation at Level 2, $1,000 per incident at Level 3, $3,000 per incident at Level 4, and $5,000 per violation at Level 5, plus $1,000 for maltreatment the licensee is responsible for.4 A core or full survey with no violations earns a 10 percent discount on your next renewal fee.4
Clinical deadlines surveyors check
These timelines apply once comprehensive services begin:
| Requirement | Deadline | Source |
|---|---|---|
| Initial assessment, in person, by an RN (or the relevant licensed health professional) | Within 5 days after services first start | 5 |
| First monitoring and reassessment, in the client’s home | No more than 14 days after services start | 5 |
| Ongoing monitoring and reassessment (may be done by telecommunication) | As needs change, and no more than 90 days after the last assessment | 5 |
| Medication management assessment, face to face | Before medication management begins; reassessed at least annually | 6 |
| Prescription renewal | At least every 12 months | 6 |
| Treatment and therapy orders renewed | At least every 12 months | 7 |
| Direct supervision of staff doing delegated tasks | Within 30 days of first delegated task | 10 |
| Orientation to home care law | Before staff provide services | 9 |
| Annual training for direct care staff | At least 8 hours per 12 months of employment | 9 |
When an RN delegates medication administration to an unlicensed staff member, the RN must first teach that person the method and see them perform it competently. The RN must also write client-specific instructions into the client record.6 Only a nurse or pharmacist may take a verbal prescription order.6
Unlicensed staff who perform delegated nursing tasks must meet one of three standards:8
- pass Minnesota’s training plus a written or oral test and a practical skills test
- meet Medicare’s training or competency requirements for home health aides or nursing assistants
- have completed a commissioner-approved nursing assistant course before April 19, 1993
At the comprehensive level, an RN conducts the training and competency evaluation, or another instructor teaches together with an RN. Seven extra topics are required, including vital signs, safe transfers, range of motion and positioning, and administering medications or treatments.8 If you plan Medicare certification, the federal home health aide standard sets the bar: 75 hours of training, with at least 16 classroom hours before at least 16 hours of supervised practical training, followed by at least 12 hours of in-service training every 12 months.18
Medicare: the full license first, and a federal freeze
MDH states that “All Medicare certified HHAs must hold a comprehensive home care license.”14 Neither a temporary comprehensive licensee nor a basic licensee is eligible for Medicare. You can apply only after you have been found in substantial compliance on the initial full survey and hold the full comprehensive license.1315
MDH’s Initial Medicare Certification form, dated July 17, 2026, sets out the rest:15
- The agency must provide skilled nursing plus at least one of physical therapy, speech-language pathology, occupational therapy, medical social services or home health aide services. At least one of these must be provided directly by the agency’s own employees.
- You email the form with CMS-1572, CMS-1561 and the HHS Office for Civil Rights assurance of compliance to [email protected], and you file CMS-855A with the Medicare Administrative Contractor.
- An approved accrediting organization can conduct the initial Medicare survey. MDH schedules its own surveys by CMS workload priorities.
- MDH sends a recommendation, and CMS makes the final decision.
Federal rules also require a new agency to show “initial reserve operating funds.” The amount must cover operations for the first three months after Medicare billing privileges are granted, and borrowed funds and lines of credit need separate proof.17
Medicare itself is closed to new agencies. A CMS moratorium on Medicare enrollment of new home health agencies took effect nationwide on May 13, 2026. It runs six months and can be extended in six-month increments. Agencies that apply within six months after it is lifted will be screened at the “high” risk level.16 As of 2026-10-12, a Federal Register search found no extension notice, so the first period ends around mid-November 2026. Buying a recently enrolled agency does not get around the freeze. A non-exempt change in majority ownership within 36 months of the agency’s initial enrollment requires a new enrollment and a new survey or accreditation.16
How Minnesota Medical Assistance pays, and what that means now
Minnesota’s Medicaid statute defines “home health agency” as “a home care provider agency that is Medicare-certified.” Home care therapies must come from a Medicare-certified agency enrolled with Medicaid.19 While the Medicare moratorium lasts, a new comprehensive licensee cannot bill MA for home health aide visits, skilled nurse visits or home care therapies. The MA rules for those services allow at most one aide visit a day, and nine face-to-face skilled nurse visits per calendar year without prior authorization.19
Home care nursing, the hourly nursing benefit, works differently. A “home care nursing agency” is defined as an MA-enrolled provider licensed under chapter 144A. Medicare certification is not part of that definition.20
Home health agencies were not on DHS’s January 2026 list of high-risk services. That list includes CFSS and PCA agencies, companion care, individualized home supports, integrated community supports, night supervision, adult day care and several behavioral health services.21 CMS approved extending the enrollment moratorium for 12 of the 14 high-risk services from July 27, 2026 through January 27, 2027.22 If your plan adds CFSS or 245D services to a comprehensive license, check that service’s enrollment status with DHS first.
Renewal fees
A full license is issued for up to one year at a time.3 Renewal fees are based on home care revenue from the previous calendar year. You may pay the top fee instead of reporting revenue. Knowingly underreporting revenue carries a penalty of double the correct fee.2
| Prior-year home care revenue | Renewal fee |
|---|---|
| $25,000 or less | $231 |
| $25,001 to $50,000 | $462 |
| $50,001 to $100,000 | $577 |
| $100,001 to $250,000 | $957 |
| $250,001 to $350,000 | $1,434 |
| $350,001 to $450,000 | $1,913 |
| $450,001 to $550,000 | $2,391 |
| $550,001 to $650,000 | $2,870 |
| $650,001 to $750,000 | $3,347 |
| $750,001 to $850,000 | $3,826 |
| $850,001 to $950,000 | $4,304 |
| $950,001 to $1,100,000 | $4,783 |
| $1,100,001 to $1,275,000 | $5,739 |
| $1,275,001 to $1,500,000 | $6,695 |
| More than $1,500,000 | $7,651 |
A license cannot be transferred. A buyer must apply for a new license, which costs the same $4,200, before acquiring a home care business or a controlling interest in one. Any transfer of 50 percent or more of the controlling interest counts as a change of ownership.2
Changes in the 2026 session
Two 2026 laws amend the home care statutes. The Revisor’s compiled text checked on 2026-10-12 does not yet include them.
- Change of ownership. Laws 2026, chapter 95, article 3, section 6 makes a new licensee responsible for any fines outstanding at a change of ownership and for corrections already ordered. Section 7 of the same article amends the fine statute (144A.474, subd. 11): a licensee can no longer avoid a fine by selling or transferring the program, and the new licensee after a change of ownership owes fines assessed after the change regardless of the violation date. The fine amounts themselves are unchanged.23
- FQHC exemption. Laws 2026, chapter 121, article 2, section 3 exempts federally qualified health centers from home care licensure when they provide certain federally defined nursing services.24
Chapter 121, article 2, section 3 states that it is effective the day following final enactment.24 The text of chapter 95, article 3, sections 6 and 7 carries no section-specific effective date, so the official sources do not settle when the change-of-ownership fine rule starts to apply. If you are buying an existing agency, ask MDH’s Home Care Program (651-201-4200) which fines and corrections would pass to you.
Sources
- 1
- 2
- 3
- 4
- 5
- 6
- 7
- 8
- 9
- 10
- 11
- 12
- 13 Minnesota Department of Health, Home Care Agency Application Materials Checked 12 Oct 2026 · Back to text ↑
- 14 Minnesota Department of Health, Medicare Certified Home Health Agencies (HHA) Checked 12 Oct 2026 · Back to text ↑
- 15
- 16
- 17
- 18
- 19
- 20
- 21 Minnesota Department of Human Services, MHCP Provider News, January 27, 2026 Checked 12 Oct 2026 · Back to text ↑
- 22 Minnesota Department of Human Services, MHCP Provider News, July 14-27, 2026 Checked 12 Oct 2026 · Back to text ↑
- 23
- 24
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Related guides
- Minnesota basic home care license: starting a non-medical home care agencyMinnesota · Non-medical home care agency
- Minnesota assisted living facility license: MDH rules, fees and stepsMinnesota · Assisted living facility
- Minnesota adult day services license: Rule 223 centers, the 2026 moratorium and the home optionMinnesota · Adult day care
- Minnesota adult foster care license: the live-in rule, four beds and county-led licensingMinnesota · Small residential care home
Minnesota and neighboring states
Compare all 51| State | License | Who needs it | State fee |
|---|---|---|---|
| Minnesota (this guide) | Comprehensive Home Care License (required for Medicare-certified home health agencies) | Skilled in-home care; required for Medicare-certified agencies | $4,200 (basic level: $2,100) |
| Wisconsin | Home Health Agency license | Skilled nursing or therapy delivered in clients' homes | $300 nonrefundable + $15 per background check |
| North Dakota | Home health agency license | Skilled nursing plus another therapy or aide service in clients' homes | See guide |
Shortened from each state's guide and our 51-state table, as of each guide's last review. Fees are the state's own; local permits and background checks cost extra.