::hero{eyebrow="Georgia Medicaid" headline="Georgia Medicaid Personal Care Services" subhead="How Section 1905(a)(24) of the Social Security Act, Section 1915(c) HCBS waiver authority, Section 1915(j) self-direction, the 21st Century Cures Act Electronic Visit Verification mandate, the Olmstead decision, and Georgia's four nursing-facility-level-of-care waivers plus the two ICF/IID-level waivers combine to deliver personal care for older adults and people with disabilities who want to remain in their homes and communities."} ::

Personal care services are the foundation of community living for older adults and people with disabilities. A personal care worker helps with the activities of daily living that are required to live safely in one's own home: bathing, dressing, toileting, transferring from bed to chair, eating, walking, and maintaining continence. They also help with the instrumental activities of daily living that make a home function: meal preparation, light housekeeping, laundry, shopping, and medication reminders. For many people, the difference between staying in their home and moving to a nursing facility is the availability of a few hours of personal care help each day.

In Georgia, personal care services are covered by Medicaid but only through a specific set of pathways. Unlike California's In-Home Supportive Services program or New York's Consumer Directed Personal Assistance Program, Georgia has not elected the optional state plan personal care services benefit available under Section 1905(a)(24) of the Social Security Act. Instead, Georgia delivers personal care services through six home and community-based services waivers authorized under Section 1915(c): the Community Care Services Program (CCSP), the Service Options Using Resources in Community Environments (SOURCE) waiver, the Independent Care Waiver Program (ICWP), the New Options Waiver (NOW), and the Comprehensive Supports Waiver Program (COMP). Children may access limited personal care services through Katie Beckett TEFRA Medicaid combined with the EPSDT medical necessity standard.

This delivery structure has major implications. Enrolling in Medicaid alone does not provide access to personal care services. The individual must qualify for one of the waivers, meet the corresponding institutional level of care, and complete waiver enrollment. Two of the waivers (NOW and COMP) have multi-year waitlists. The 21st Century Cures Act of 2016 added Electronic Visit Verification requirements that affect every personal care services visit. Self-direction is available but underutilized. Family caregiver eligibility rules vary substantially across the waivers, with spouses generally excluded in the elderly and physical disability waivers but eligible under the IDD waivers' Live-In Family Caregiver option.

This guide translates the personal care services framework for Georgia families. It covers the federal authorities (Section 1905(a)(24), Section 1915(c), Section 1915(j) self-direction, Section 1915(k) Community First Choice, the 21st Century Cures Act EVV mandate, Olmstead, the HCBS Settings Rule, the FLSA Home Care Final Rule, and IRS Notice 2014-7), the Georgia implementation (DCH waiver manuals, the Division of Aging Services, the 12 Area Agencies on Aging, the Division of Developmental Disabilities, and the four Care Management Organizations), the service delivery models (agency, Structured Family Caregiving, Live-In Family Caregiver, self-direction), the EVV requirements, the family caregiver eligibility rules, the registered nurse delegation framework for health-related tasks, and how to access personal care services through each waiver. Six worked examples illustrate how personal care services work for real Georgia families. A frequently asked questions section addresses the most common questions families ask. A contact directory provides the phone numbers needed to navigate the system.

::callout{title="Key takeaways"}

  • Georgia does NOT have a stand-alone state plan personal care services benefit. Personal care services are available only through the six home and community-based services waivers (CCSP, SOURCE, ICWP, NOW, COMP) or through limited Katie Beckett TEFRA plus EPSDT for children.
  • Section 1915(c) of the Social Security Act authorizes the waivers, which require nursing facility level of care (CCSP, SOURCE), ICF for individuals with hospital level of care (ICWP), or ICF/IID level of care (NOW, COMP).
  • Self-direction is available in CCSP, ICWP, NOW, and COMP. Self-direction means the participant has employer authority over their workers (hiring, scheduling, supervising, firing) and may have budget authority over an authorized cash allotment. A financial management service handles payroll, taxes, and workers compensation.
  • The 21st Century Cures Act of 2016 requires Electronic Visit Verification for every personal care services visit. Georgia implements EVV through a state-contracted data aggregator that providers connect to for visit verification.
  • Spouses cannot be paid as personal care workers in CCSP, SOURCE, or ICWP. Spouses and parents of adult IDD individuals CAN be paid as Live-In Family Caregivers under NOW and COMP.
  • Structured Family Caregiving allows an adult family member or non-family caregiver who lives with or provides primary caregiving for a CCSP or SOURCE participant to receive a monthly stipend tiered to the level of care needed.
  • IRS Notice 2014-7 excludes Medicaid waiver difficulty-of-care payments to live-in caregivers from federal income tax when the caregiver lives in the same home as the care recipient.
  • Personal care workers are non-clinical and cannot administer medications. A registered nurse may delegate certain health-related tasks (vital signs, medication assistance, simple wound care, glucometer use) under the Georgia Board of Nursing's RN Delegation Rule. ::

The federal framework

By Brevy Care Team · Last verified May 12, 2026

Section 1905(a)(24) and 42 CFR 440.167

Personal care services is an optional Medicaid state plan benefit defined at Section 1905(a)(24) of the Social Security Act (42 USC 1396d(a)(24)). The implementing regulation at 42 CFR 440.167 defines personal care services as services that are authorized by a physician under a plan of treatment or, at state option, otherwise authorized under a service plan approved by the state, provided by an individual who is qualified to provide the services and who is not a member of the individual's family, and furnished in a home or, at state option, in another location.

States that elect the state plan personal care services option must offer the benefit statewide and on a comparable basis to all categorically eligible Medicaid beneficiaries. This statewideness and comparability requirement at Section 1902(a)(10)(B) is one major reason states often deliver personal care services through Section 1915(c) waivers instead. Waivers allow states to target specific populations (people meeting nursing facility level of care, for example) and to limit benefits geographically or by enrollment cap.

California's In-Home Supportive Services program, New York's Consumer Directed Personal Assistance Program, Washington's Community First Choice program, and a few other state programs draw on the state plan personal care services option, Section 1915(k) Community First Choice, or Section 1915(i). Georgia has not elected any of these state plan options. As a result, personal care services in Georgia are available only through Section 1915(c) waivers and a small number of related pathways.

Section 1915(c) home and community-based services waivers

Section 1915(c) of the Social Security Act (42 USC 1396n(c)) authorizes states to waive certain Medicaid requirements (statewideness, comparability, and income/resource rules for institutionalized individuals) to provide home and community-based services as an alternative to institutional care. The implementing regulations at 42 CFR 441.300-310 describe waiver application requirements, person-centered service planning, quality assurance, and conflict-of-interest standards.

Section 1915(c) waivers must demonstrate cost neutrality, meaning average per-participant home and community-based services costs cannot exceed average per-participant institutional costs. Personal care services is one of the most commonly covered Section 1915(c) waiver services. Georgia delivers personal care services through six different 1915(c) waivers, each targeting a different population.

Section 1915(j) self-directed personal assistance services

Section 1915(j) of the Social Security Act (42 USC 1396n(j)) was added by the Deficit Reduction Act of 2005 to allow states to offer self-directed personal assistance services as a state plan option without a waiver. Self-direction means the participant has employer authority (hiring, scheduling, supervising, training, and firing their workers) and may have budget authority (allocating an authorized cash allotment across approved services).

Section 1915(j) emerged from the Cash and Counseling Demonstration that ran from 1996 through 2005 in Arkansas, Florida, and New Jersey. The demonstration found participants who self-directed reported higher satisfaction with services, had fewer unmet needs, and experienced fewer adverse events than those receiving traditional agency-direction. Georgia has not elected the standalone Section 1915(j) state plan option but offers self-direction within its Section 1915(c) waivers.

Section 1915(k) Community First Choice

Section 1915(k) of the Social Security Act (42 USC 1396n(k)) was added by Section 2401 of the Affordable Care Act of 2010 to create the Community First Choice state plan option. Community First Choice provides an enhanced federal match for attendant services and supports for individuals with disabilities who would otherwise require an institutional level of care. A number of states have implemented Community First Choice. Georgia has not implemented Community First Choice, which is a significant policy gap given the enhanced federal match available.

21st Century Cures Act Section 12006: Electronic Visit Verification

Section 12006 of the 21st Century Cures Act of 2016 (Public Law 114-255) amended Section 1903(l) of the Social Security Act to require state Medicaid agencies to implement Electronic Visit Verification systems for personal care services and home health care services. Personal care services EVV was required under the mandate first, with a phase-in period for states that demonstrated good faith effort. Home health care services EVV was required under a later deadline.

EVV systems must verify six data elements for each visit: the type of service performed, the individual receiving the service, the date of the service, the location of service delivery, the individual providing the service, and the time the service begins and ends. States that fail to implement compliant EVV face graduated federal financial participation reductions.

States may use one of three EVV implementation models: state-mandated external vendor, state-mandated state-developed system, or provider-choice with state aggregator. Georgia uses the provider-choice with state aggregator model.

Olmstead v. L.C. and the ADA

The Supreme Court's 1999 decision in Olmstead v. L.C. held that unjustified institutionalization of people with disabilities is discrimination under Title II of the Americans with Disabilities Act. States must provide community-based services when the state's treatment professionals determine the placement is appropriate, the individual does not oppose community placement, and the placement can be reasonably accommodated taking into account state resources and the needs of others with disabilities.

Olmstead is the legal foundation for HCBS rebalancing efforts including personal care services. Georgia entered into a 2010 Settlement Agreement with the United States Department of Justice (United States v. State of Georgia) addressing community integration for individuals with intellectual and developmental disabilities and individuals with mental illness who were institutionalized at Georgia state psychiatric hospitals. The settlement required Georgia to expand HCBS capacity including personal care services for individuals transitioning out of institutional settings.

Money Follows the Person

The Money Follows the Person rebalancing demonstration, authorized by Section 6071 of the Deficit Reduction Act of 2005 and extended by Section 2403 of the Affordable Care Act, helps states transition individuals from institutional settings to community-based settings. The Consolidated Appropriations Act of 2023 reauthorized Money Follows the Person through fiscal year 2027.

Money Follows the Person funds enhanced services during transition and the first 365 days post-transition. Personal care services is typically a core Money Follows the Person service. Georgia's Money Follows the Person program has transitioned thousands of individuals from nursing facilities, ICFs/IID, and state psychiatric hospitals into community settings.

HCBS Settings Rule

The HCBS Settings Rule, promulgated in 2014 and subsequently amended, establishes federal standards for home and community-based settings under Sections 1915(c), 1915(i), 1915(k), and 1115. Settings must be integrated in and support full access to the greater community, be selected by the individual from among setting options including non-disability-specific options, ensure individual rights of privacy, dignity, respect, and freedom from coercion, optimize individual initiative and autonomy in making life choices, and facilitate individual choice regarding services and supports.

For personal care services, the Settings Rule means that participants receiving services in their own homes retain full rights to control their schedules, visitors, and daily activities. Group residential settings serving personal care recipients must meet additional standards.

FLSA Home Care Final Rule

The Department of Labor's 2013 Home Care Final Rule (effective January 2015 after litigation delay) extended Fair Labor Standards Act minimum wage and overtime protections to home care workers who had previously been classified as exempt companions. The rule narrowed the companionship exemption to apply only to workers performing fellowship and protection without medication assistance or housework, and only when the worker is employed by the consumer or household, not by an agency.

For Medicaid personal care services, the rule means home care workers employed by agencies must receive minimum wage and overtime pay for hours over 40 per week. Workers self-directed by participants are typically considered jointly employed by the participant and the financial management service, and FLSA wage protections apply. Many states have implemented overtime caps that limit individual workers to a maximum number of hours per week to manage Medicaid budgets.

IRS Notice 2014-7: Difficulty of Care Exclusion

IRS Notice 2014-7 provides that certain Medicaid waiver payments to live-in providers caring for individuals in the provider's home are excludable from gross income under Section 131 of the Internal Revenue Code as difficulty of care payments. The exclusion applies when the care recipient is a qualified foster individual under Section 131(b)(2), which the IRS interpreted to include Medicaid waiver care recipients, and the payments are received under a state's Medicaid HCBS waiver.

For Georgia, the practical effect is that paid family caregivers who live with the Medicaid waiver participant may exclude Medicaid waiver payments from federal income tax. This applies to NOW or COMP participants receiving Live-In Family Caregiver services and to CCSP or SOURCE participants receiving Structured Family Caregiving where the caregiver lives in the same home. The exclusion does NOT apply to non-live-in caregivers or to non-Medicaid-funded caregiving income.

The Georgia framework

Georgia does NOT have stand-alone state plan personal care services

This is the single most important threshold fact for Georgia families. Unlike California (IHSS), New York (CDPAP), or Washington (Community First Choice), Georgia has NOT elected the state plan personal care services option under Section 1905(a)(24) or the Community First Choice option under Section 1915(k). Enrollment in Medicaid alone does not provide access to personal care services.

To receive personal care services through Georgia Medicaid, the individual must qualify for one of the home and community-based services waivers (CCSP, SOURCE, ICWP, NOW, or COMP) or, for children, must qualify for Katie Beckett TEFRA Medicaid with personal care services authorized through the EPSDT medical necessity standard. The waiver enrollment process can take weeks to months for CCSP, SOURCE, and ICWP, and years for NOW and COMP.

CCSP: Community Care Services Program

CCSP serves frail elderly individuals age 65 or older and adults age 18 to 64 with physical disabilities who meet nursing facility level of care. CCSP is administered by the Division of Aging Services within the Department of Human Services and operated through the 12 Area Agencies on Aging that cover the state. CCSP offers a menu of home and community-based services including personal support services (the CCSP term for personal care), adult day health services, home-delivered meals, emergency response services, and respite.

Personal support services in CCSP can be delivered through an agency provider or through Structured Family Caregiving. The agency model uses a licensed home care agency that employs the caregiver. Structured Family Caregiving allows a family caregiver or other identified caregiver who lives with or provides primary care for the participant to receive a monthly stipend through a state-contracted vendor. The stipend is tiered (Tier 1, Tier 2, or Tier 3) based on functional assessment and reflects the intensity of care needed.

CCSP also offers self-direction. Participants who self-direct have employer authority over their personal support service workers and may have budget authority over an authorized cash allotment. A financial management service handles payroll, taxes, workers compensation, and EVV compliance.

SOURCE: Service Options Using Resources in Community Environments

SOURCE serves the same population as CCSP (frail elderly and adults with physical disabilities meeting nursing facility level of care) but adds enhanced care coordination through an enrolled primary care physician. A SOURCE care coordinator coordinates Medicaid services, Medicare services where applicable, and community resources. Personal care in SOURCE follows the same scope and rules as CCSP, including the option for agency-based delivery, Structured Family Caregiving, or self-direction.

SOURCE is particularly useful for individuals with complex medical needs who benefit from a tightly integrated primary care plus community supports model. The SOURCE care coordinator typically works closely with the PCP and the SOURCE network providers to manage transitions of care, prevent avoidable hospitalizations, and address social drivers of health.

ICWP: Independent Care Waiver Program

ICWP serves adults age 21 to 64 with physical disabilities who meet the institutional level of care for an intermediate care facility for individuals with hospital level of care (ICF/H), which is comparable to skilled nursing facility level of care. ICWP often serves individuals with traumatic brain injury and spinal cord injury. Personal support services is a core ICWP benefit and can be delivered through agency providers or self-direction. The ICWP self-direction model includes employer authority, budget authority, and financial management services support.

NOW: New Options Waiver

NOW serves individuals with intellectual or developmental disabilities (IDD) who meet ICF/IID level of care. NOW has an annual per-participant service cap, which is meaningful but may not be enough to cover round-the-clock supports. NOW is administered by the Division of Developmental Disabilities within the Department of Behavioral Health and Developmental Disabilities. Personal support services is one of the most-used NOW services, along with community access, supported employment, and respite.

NOW includes a Live-In Family Caregiver option that allows family members including parents and spouses to be paid as the participant's caregiver when they live with the participant. This is a critical flexibility for families. The Live-In Family Caregiver receives Medicaid waiver payments that may be excludable from federal income tax under IRS Notice 2014-7.

The NOW waitlist is long, typically several years. The state has worked to reduce the waitlist through state budget appropriations and federal funding but the waitlist remains a major access barrier.

COMP: Comprehensive Supports Waiver Program

COMP serves individuals with IDD who require more intensive supports than NOW provides. COMP has no annual cap on services and includes options such as Host Home (a family-style residential setting where the participant lives with a contracted provider) and Community Residential Alternative (a small group home). COMP also includes the Live-In Family Caregiver option, allowing parents, spouses, or other adult family members who live with the participant to be paid as caregivers.

The COMP waitlist is even longer than the NOW waitlist, often 5 to 10 years or more for individuals who do not qualify for crisis priority. Families generally apply early and pursue NOW or alternate supports while waiting for COMP.

Katie Beckett TEFRA and EPSDT for children

Children who do not meet ICF/IID level of care for NOW or COMP, or who are waiting for NOW or COMP enrollment, may access limited personal care services through Katie Beckett TEFRA Medicaid combined with EPSDT (Early and Periodic Screening, Diagnostic, and Treatment) under Section 1905(r)(5) of the Social Security Act. EPSDT requires Medicaid to cover any service that is medically necessary for a child under age 21, even if the service is not in the state plan for adults. Personal care services for a child with significant disability can be authorized under EPSDT medical necessity if a physician documents the need and the services prevent institutionalization.

The Division of Aging Services and the 12 Area Agencies on Aging

The Division of Aging Services within the Georgia Department of Human Services administers CCSP and SOURCE. Day-to-day care management is performed by 12 Area Agencies on Aging that cover the state geographically:

  1. Atlanta Regional Commission AAA
  2. Coastal Georgia Regional Commission AAA
  3. Georgia Mountains AAA
  4. Heart of Georgia Altamaha AAA
  5. Legacy Link AAA
  6. Middle Georgia AAA
  7. Northeast Georgia AAA
  8. Northwest Georgia AAA
  9. River Valley AAA
  10. Southern Georgia AAA
  11. Southwest Georgia AAA
  12. Three Rivers AAA

Each AAA operates an Aging and Disability Resource Connection (ADRC) call line at 1-866-552-4464 (GeorgiaCares). The ADRC is the primary entry point for CCSP and SOURCE applications and information.

The Division of Developmental Disabilities

The Division of Developmental Disabilities within the Department of Behavioral Health and Developmental Disabilities administers NOW and COMP. DDD operates Regional Field Offices across the state. Families applying for NOW or COMP register through the Regional Field Office, complete a functional assessment using the Supports Intensity Scale, and are placed on the NOW or COMP waitlist.

The four Care Management Organizations

Most Medicaid members in Georgia are enrolled in managed care through one of four Care Management Organizations: Amerigroup Community Care, CareSource Georgia, Peach State Health Plan, and Wellpoint Georgia. CMOs cover acute care services (hospital, physician, pharmacy, behavioral health). The waivers themselves (CCSP, SOURCE, ICWP, NOW, COMP) operate on a fee-for-service basis outside CMO benefit packages, but the participant's acute care benefits continue to flow through the CMO. Care coordination between the waiver care coordinator and the CMO care manager is important to avoid duplicate services or gaps.

Service delivery models

Agency-based personal care

The agency model is the traditional delivery structure. A licensed home care agency employs the caregiver, handles scheduling, supervision, payroll, taxes, workers compensation, and EVV compliance. The participant has minimal employer responsibilities but also less control over scheduling and worker selection. The agency typically assigns workers based on availability and may rotate workers across multiple clients, which can disrupt continuity.

Agency-based services are billed to the waiver at established fee schedule rates per 15-minute unit. Rates typically fall in the range of four to six dollars per 15-minute unit for routine ADL and IADL assistance, which translates to roughly $16 to $24 per hour. Agencies retain a portion of the reimbursement to cover overhead, with the worker receiving the balance as wages.

Structured Family Caregiving (CCSP and SOURCE)

Structured Family Caregiving is a flexibility within CCSP and SOURCE that recognizes the central role of family caregivers in elderly and disabled adult care. A family caregiver (adult child, sibling, niece or nephew, or non-family caregiver living in the same home) receives a monthly stipend through a state-contracted Structured Family Caregiving agency. The stipend is tiered:

  • Tier 1: Lower-intensity needs (some ADL assistance, monitoring, IADL help). Annualized stipend roughly $25,000 to $30,000.
  • Tier 2: Moderate-intensity needs (substantial ADL assistance, regular supervision). Annualized stipend roughly $32,000 to $40,000.
  • Tier 3: High-intensity needs (full ADL dependence, complex medical or behavioral needs, near-constant supervision). Annualized stipend roughly $40,000 to $48,000.

The Structured Family Caregiving agency provides a care coach who supports the family caregiver with caregiving strategies, behavioral support, and care plan oversight. Monthly home visits and check-ins are typical. The care coach is also responsible for monitoring the participant's safety and well-being.

Structured Family Caregiving is an excellent option for adult children who have left employment to care for an aging parent, for spouses who are not eligible for paid caregiving under the standard rules but can serve as a non-paid primary caregiver while a different live-in family member receives the stipend, or for individuals who prefer family-based care over agency-based care.

Live-In Family Caregiver (NOW and COMP)

The NOW and COMP waivers' Live-In Family Caregiver option allows immediate family members including parents and spouses to be paid as the participant's caregiver when they live with the participant. This is a unique flexibility in the IDD waivers that the elderly/physical disability waivers (CCSP, SOURCE, ICWP) do not offer.

The Live-In Family Caregiver is paid for hours that exceed the typical parental or spousal obligation. For a young adult with significant IDD living with parents, this might represent the bulk of the parental caregiving time. For a spouse caring for a partner with IDD, the paid hours are similarly substantial.

Live-In Family Caregivers are paid through a financial management service that handles payroll, tax withholding, and workers compensation. The IRS Notice 2014-7 difficulty of care exclusion typically applies, meaning the Medicaid waiver payments are excludable from federal income tax.

Consumer-Directed Care (self-direction)

Self-direction is available in CCSP, ICWP, NOW, and COMP. Under self-direction the participant has employer authority over their workers (recruiting, hiring, training, scheduling, supervising, and firing) and may have budget authority over an authorized cash allotment that can be allocated across approved services.

A financial management service acts as the participant's fiscal/employer agent. The FMS issues payroll to workers, withholds taxes, files required tax forms (W-2 or 1099), pays workers compensation insurance, and handles the EVV data flow. The participant remains the common law employer for purposes of hiring, supervising, and firing, but the FMS handles all the administrative employer functions.

Self-direction allows the participant to recruit non-traditional caregivers including neighbors, friends, church members, or extended family. This is particularly valuable in rural areas where agency capacity is limited and in cultural communities where formal home care agencies may not have culturally or linguistically concordant workers.

The Georgia self-direction program is co-employment model, meaning the participant is the common law employer and the FMS is the administrative employer. Workers are typically considered jointly employed by the participant and the FMS for FLSA wage and hour purposes.

Electronic Visit Verification in Georgia

The 21st Century Cures Act EVV mandate affects every Medicaid-funded personal care services visit and every Medicaid-funded home health care services visit in Georgia. Georgia implements EVV through a state aggregator model. Tellus, which is part of HHAeXchange, is the state's contracted EVV data aggregator. Sandata is an alternate state-approved EVV vendor. Providers may use Tellus' system directly, use Sandata, or use their own EVV system that interfaces with Tellus through approved data integration.

The six federally required EVV data elements are captured for each visit:

  1. The type of service performed
  2. The individual receiving the service
  3. The date of the service
  4. The location of service delivery
  5. The individual providing the service
  6. The time the service begins and ends

Caregivers verify visits using one of three methods: a mobile app on a smartphone with GPS location verification, telephony where the caregiver calls a toll-free number from the participant's home phone, or a fixed visit verification device installed in the participant's home that the caregiver activates.

Common EVV compliance issues include:

  • Caregivers forgetting to clock in at the start of a visit
  • Caregivers forgetting to clock out at the end of a visit
  • GPS issues in rural areas with poor cell coverage
  • Technology gaps for older caregivers who are not comfortable with smartphone apps
  • Visit time gaps when caregivers do not capture the full visit
  • Participant home phone disconnected or non-functional, blocking telephony

EVV non-compliance can result in claim denial or recoupment. Self-directed participants and their family caregivers must be trained on the EVV process. The financial management service typically provides EVV training and ongoing support.

Family caregiver eligibility rules

The rules about who can be paid as a personal care worker are some of the most confusing and most consequential rules in Georgia Medicaid. The rules vary substantially across the six waivers.

Generally CANNOT be paid

  • Spouses of CCSP, SOURCE, or ICWP participants
  • Parents of minor child Medicaid recipients (except in narrow EPSDT or Katie Beckett circumstances)
  • Legal guardians of adult Medicaid recipients in many cases

CAN be paid

  • Adult children of an elderly or disabled adult parent (CCSP, SOURCE, ICWP through agency or, for CCSP/SOURCE, through Structured Family Caregiving)
  • Siblings of an adult Medicaid recipient (most waivers)
  • Other adult relatives (most waivers)
  • Friends, neighbors, and other non-relatives (with required training and background check)
  • Parents of an adult IDD individual (NOW, COMP through Live-In Family Caregiver)
  • Spouses of NOW/COMP participants (Live-In Family Caregiver)
  • Adult children of NOW/COMP participants (Live-In Family Caregiver or standard PCS)

Why spouses are generally excluded in elderly/physical disability waivers

The spouse exclusion in CCSP, SOURCE, and ICWP reflects the historical Medicaid policy that spousal caregiving is part of the marital relationship and therefore not separately compensable through Medicaid. The exclusion was relaxed in the IDD waivers (NOW and COMP) to recognize the often-lifetime caregiving role that parents play for adult children with IDD and the analogous role that spouses sometimes play. Federal CMS policy has gradually relaxed in recent years to permit spousal caregiver payment in more circumstances, but Georgia has not extended that flexibility to CCSP, SOURCE, or ICWP as of 2026.

Worker requirements

All paid personal care workers must:

  • Pass a Georgia Crime Information Center (GCIC) background check
  • Pass a national fingerprint-based background check
  • Complete CPR and basic first aid training
  • Complete training on activities of daily living and instrumental activities of daily living
  • Complete training on recognition and reporting of abuse, neglect, and exploitation
  • Complete training on person-centered care principles
  • Complete training on HIPAA privacy and infection control

For NOW and COMP participants with complex needs, additional training requirements apply including positive behavior support, communication strategies, and crisis prevention.

Certain criminal convictions (specified in the DCH provider manuals) disqualify a worker permanently. Other convictions may require a waiver review.

Personal care workers are non-clinical and cannot administer medications, perform skilled procedures, or make clinical assessments. However, the Georgia Board of Nursing's Registered Nurse Delegation Rule permits a registered nurse to delegate certain health-related tasks to a personal care worker under specific conditions. Delegable tasks may include:

  • Vital signs measurement (blood pressure, pulse, temperature, respirations)
  • Medication assistance: reminding the participant to take medication, prompting, opening containers, handing the medication to the participant (but NOT administering the medication directly to the participant)
  • Simple wound care under an RN-developed care plan
  • Glucometer use for blood sugar checks
  • Ostomy care
  • Catheter care including external catheter and Foley catheter maintenance (but generally not insertion)
  • Tube feedings via established gastrostomy

The RN must:

  1. Assess the participant's needs and stability
  2. Determine that the task is appropriate for delegation
  3. Verify the worker's competency through training and supervised performance
  4. Document the delegation in writing
  5. Supervise the worker periodically as required by the Board of Nursing rules
  6. Be available for consultation
  7. Retain accountability for the delegated task

Delegation is task-specific and worker-specific. An RN cannot delegate a task to a worker who has not been trained and verified by that specific RN. The delegation does not transfer the RN's professional liability to the worker.

Hours allocation and care planning

Functional assessment

Hours are allocated based on a standardized functional assessment. Georgia uses the Determination of Need-Revised (DON-R) instrument for CCSP, SOURCE, and ICWP. The DON-R assesses functional status across ADLs, IADLs, supervision needs, behavioral concerns, and continence. The result is a score that maps to authorized hours per week or per month.

NOW and COMP use the Supports Intensity Scale (SIS), which is a comprehensive assessment of support needs across daily activities, community activities, lifelong learning, employment, health and safety, and social activities. COMP adds a separate health and safety screen for risk of harm to self or others.

Care plan development

Once authorized hours are determined, a person-centered service plan is developed in collaboration with the participant, family members or guardians, the care coordinator, and chosen providers. The plan documents:

  • The participant's preferences, strengths, and goals
  • The supports and services needed to achieve those goals
  • The amount, frequency, and duration of each service
  • The providers responsible for each service
  • The backup plan for caregiver absence
  • The risk mitigation strategies for known risks (falls, wandering, medication non-adherence, behavioral crises)
  • The participant's signature indicating consent

Care plans are reviewed quarterly by the care coordinator and updated when there are significant changes in the participant's condition or circumstances. Annual reassessment using the DON-R or SIS is required to maintain waiver enrollment and to adjust hours.

Hours flexibility

Authorized hours may be flexed within the total. For example, a participant authorized 20 hours per week could receive 25 hours one week and 15 hours the next, as long as the monthly total stays within the authorization. Hours generally cannot be banked or rolled forward to subsequent service periods, although limited flexibility exists for vacation coverage or planned hospitalizations.

Reduction appeals

Participants whose hours are reduced or whose services are terminated have appeal rights under 42 CFR 431.200 et seq. The Medicaid Fair Hearing process requires advance written notice (typically 10 days before the change), opportunity for a hearing before an administrative law judge, right to representation, right to present evidence and cross-examine, and a written decision. Aid paid pending appeal is available if the appeal is filed within 10 days of notice, meaning services continue at the prior level until the hearing decision.

Cost and reimbursement

Reimbursement rates

Agency-based personal care services in Georgia is reimbursed through the waiver fee schedule. Rates vary by service code and waiver but typically fall in the range of four to six dollars per 15-minute unit for routine ADL and IADL assistance. Structured Family Caregiving stipends are paid monthly based on tier, with annualized values typically in the $25,000 to $48,000 range. Live-In Family Caregiver under NOW or COMP is reimbursed at standard PCS rates adjusted for the live-in arrangement.

Cost neutrality and the cap on services

Section 1915(c) waiver cost neutrality requires that average per-participant home and community-based services costs do not exceed average per-participant institutional costs. CCSP, SOURCE, and ICWP must demonstrate cost neutrality against nursing facility costs. NOW and COMP must demonstrate cost neutrality against ICF/IID costs.

Cost neutrality is calculated as an average across all waiver participants, not as a hard per-person cap. NOW has an annual per-participant cap as a feature of the waiver design. COMP has no annual cap and is intended for individuals whose support needs exceed what NOW can provide.

Federal financial participation

Personal care services delivered through Section 1915(c) waivers draws the regular FMAP. Georgia's FMAP for federal fiscal year 2026 is approximately 65.50 percent, meaning the federal government pays 65.50 percent of waiver service costs and Georgia pays the remaining 34.50 percent through state appropriations. Community First Choice services (which Georgia does not offer) would draw FMAP plus six percentage points, an enhanced match that would reduce Georgia's state share.

Worked examples

Margaret, 78, Atlanta: CCSP with agency-based personal care

Margaret is a widowed retiree on Social Security and Medicare. She fell at home and now has limited mobility and moderate dementia. Her daughter Linda lives in Marietta but works full-time as a nurse and cannot leave her job to provide care. Margaret applied for CCSP through the Atlanta Regional Commission AAA after Linda called the ADRC at 1-866-552-4464. The AAA care coordinator completed a Determination of Need-Revised assessment and certified Margaret for nursing facility level of care. Margaret was enrolled in CCSP and approved for 20 hours per week of personal support services.

The CCSP care plan includes:

  • Agency-based personal support services 4 hours per day, 5 days per week (20 hours total)
  • Adult day health services Tuesday and Thursday at a community-based program
  • Home-delivered meals 5 days per week
  • Emergency response system (PERS) for fall detection
  • Annual reassessment scheduled

The agency caregiver helps Margaret with bathing, dressing, meal preparation, light housekeeping, and medication reminders. Adult day health provides socialization, structured activity, and respite for Linda on her two longest workdays. The PERS device gives Linda peace of mind that Margaret can summon help if she falls when no one is present. EVV is handled through the agency's Tellus-integrated EVV system. Linda remains involved in care decisions and visits Margaret on weekends.

Tyrell, 24, Macon: ICWP with self-direction

Tyrell sustained a severe traumatic brain injury in a motor vehicle accident at age 22. He has left-sided hemiparesis, cognitive impairment, and a seizure disorder controlled on anti-epileptic medication. After completing inpatient rehabilitation he was approved for the Independent Care Waiver Program. He elected self-direction.

Under self-direction, Tyrell's older brother Marcus serves as his primary paid caregiver, providing 35 hours per week of personal support services. The Financial Management Service handles Marcus's payroll, withholds taxes, pays workers compensation insurance, and files year-end tax forms. Marcus uses the Tellus EVV mobile app on his phone to clock in and out of each visit. Tyrell uses his budget authority to also pay a neighbor for backup coverage when Marcus is unavailable, typically two to four hours per week. The neighbor underwent the standard background check and CPR training before being added to the care team.

Tyrell's care coordinator visits monthly to review the care plan and the budget allocation. The ICWP care plan also includes occupational therapy, physical therapy, and assistive technology assessment. Tyrell uses a power wheelchair for community mobility and a transfer board for bed-to-chair transfers.

Jamil, 30, Savannah: NOW with Live-In Family Caregiver

Jamil has autism spectrum disorder with significant communication and behavioral support needs. He uses an augmentative and alternative communication device for expressive communication. He lives with his mother Aisha. The family was approved for the New Options Waiver after a 6-year waitlist.

Under NOW's Live-In Family Caregiver option, Aisha is paid as Jamil's primary caregiver. She is compensated for caregiving hours that exceed the typical parental obligation for an adult child. The Financial Management Service handles payroll. Because Aisha lives in the same home as Jamil and the payments are Medicaid waiver payments, the IRS Notice 2014-7 difficulty of care exclusion applies and the Medicaid waiver payments are excludable from Aisha's federal income tax.

Jamil's NOW care plan also includes community access services (an agency-based supports worker accompanies Jamil to community activities including a weekly adapted recreation program), supported employment exploration (Jamil is working with a job developer to identify a part-time position aligned with his interests), and behavioral consultation. Annual reassessment with the Supports Intensity Scale is scheduled. The NOW annual service cap is managed carefully across all service categories.

Diana, 82, Albany: SOURCE with Structured Family Caregiving

Diana has moderate Alzheimer's disease and lives with her daughter Lisa. Lisa quit her job as a school administrator to provide full-time care after Diana wandered out of the house at night and was found by police three blocks away. Diana was enrolled in SOURCE through the Southwest Georgia AAA. SOURCE provides enhanced care coordination through Diana's enrolled primary care physician at the Phoebe Putney Health System.

Through SOURCE, Diana was approved for Structured Family Caregiving at Tier 2. Lisa receives a monthly stipend of approximately $3,200 through the contracted Structured Family Caregiving agency. A care coach visits monthly to support Lisa with dementia caregiving strategies including communication techniques, behavioral approaches to evening agitation, safety modifications (additional door alarms, a GPS tracker on a wrist band), and care plan oversight.

SOURCE care coordination also coordinates Diana's Medicare and Medicaid benefits. Medicare covers physician visits, hospital care, and limited home health when ordered, while Medicaid through SOURCE covers the Structured Family Caregiving, adult day health (one day per week to give Lisa respite), and supplemental services. The SOURCE care coordinator helps Lisa understand which benefit covers which service and helps prevent unnecessary hospitalizations through close coordination with the PCP.

Sarah, 65, Athens: CCSP with mixed agency and respite

Sarah has multiple sclerosis with progressive disability. She uses a power wheelchair full-time and needs assistance with bathing, dressing, transfers, and toileting. Her husband Mark works full-time as a high school teacher and provides evening, overnight, and weekend care. The family applied for CCSP through the Northeast Georgia AAA when Sarah's disease progression made unassisted morning routine impossible.

Sarah was approved for CCSP and receives 25 hours per week of agency-based personal support services. The agency caregiver arrives at 7 AM Monday through Friday to help Sarah with morning bathing, dressing, and transfers, allowing Mark to leave for work by 7:45 AM. The caregiver remains for IADL support during the morning and returns for a shorter afternoon visit. Sarah also attends adult day health two days per week, which provides additional structured activity and gives Mark respite from morning caregiving duties on those days.

The CCSP care plan also includes home modifications (Sarah's home was modified with a roll-in shower and bathroom grab bars through a separate environmental modification benefit) and consumable medical supplies. Spousal caregiving by Mark is not paid because CCSP excludes spouses from paid caregiving. The family has explored whether SOURCE plus Structured Family Caregiving could enable Mark to leave teaching and become Sarah's paid caregiver, but spousal exclusion applies in SOURCE as well. The family has decided to continue the current arrangement.

David, 35, Columbus: COMP with paid father Live-In Family Caregiver

David has Down syndrome and a moderate intellectual disability. He lives with his elderly parents. As his parents have aged (mother now 72, father 75), the family needed more formal support and a longer-term plan for what happens when his parents can no longer provide care. David was on the COMP waitlist for 8 years before approval.

Under COMP, David receives day habilitation services 5 days per week at a community-based program, plus personal care hours in the evenings and on weekends. David's father serves as the paid Live-In Family Caregiver under COMP, receiving payment for hours that exceed typical parental obligation. The Financial Management Service handles payroll and the IRS Notice 2014-7 exclusion applies to the difficulty-of-care payments.

The COMP care plan also includes behavioral consultation, supported employment exploration, and Person-Centered Planning that addresses long-term residential planning. The family is working with a Special Needs Trust attorney to establish a Third Party Special Needs Trust funded by life insurance and inheritance, designed to supplement Medicaid benefits for David's future. The family is also exploring Host Home or Community Residential Alternative options for the time when David's parents can no longer provide care, ideally with a planned transition rather than a crisis transition.

Common pitfalls and how to avoid them

  1. Assuming Medicaid automatically includes personal care services. It does not in Georgia. Apply for a waiver.
  2. Missing the waiver waitlist. NOW and COMP waitlists exceed 5 years for non-crisis applicants. Register early.
  3. Choosing agency model when self-direction would better fit the family. Self-direction allows family caregiver employment, schedule flexibility, and worker continuity.
  4. Not understanding the spouse exclusion. Spouses cannot be paid in CCSP, SOURCE, or ICWP. Spouses CAN be paid in NOW and COMP under Live-In Family Caregiver.
  5. Underestimating the EVV compliance burden on family caregivers. Train caregivers on the EVV app or telephony before service starts.
  6. Failing to file IRS Notice 2014-7 exclusion when eligible. Live-in family caregivers receiving Medicaid waiver payments can exclude those payments from federal income tax. Talk to a tax professional.
  7. Not building a backup caregiver plan. Single-caregiver arrangements fail when caregivers are sick, on vacation, or in family emergencies. Have a backup plan documented in the care plan.
  8. Not appealing reduced hours. Participants have appeal rights under 42 CFR 431.200 et seq. with aid paid pending appeal available.
  9. Not coordinating with Medicare home health when applicable. Medicare home health is a separate benefit covering skilled nursing and therapies (not personal care). The two benefits can complement each other but require coordination.
  10. Failing to coordinate Katie Beckett TEFRA with EPSDT for child waiver recipients. Children may access personal care services through EPSDT medical necessity in addition to or instead of waiver services.
  11. Confusing "personal care" with "companion services." Companion services are a different benefit category that does not include hands-on ADL assistance. Personal care includes hands-on ADL help.
  12. Not requesting a reassessment after a change in condition. If a participant's needs increase (after a fall, hospitalization, or progression of illness), request a reassessment to adjust hours.

::accordion{title="Frequently asked questions"} ::accordion-item{title="Does Georgia Medicaid cover personal care services without a waiver?"} No. Georgia has not elected the state plan personal care services option under Section 1905(a)(24) of the Social Security Act or the Community First Choice option under Section 1915(k). Personal care services in Georgia are available only through the six home and community-based services waivers (CCSP, SOURCE, ICWP, NOW, and COMP) or, for children, through Katie Beckett TEFRA Medicaid combined with the EPSDT medical necessity standard. :: ::accordion-item{title="What is the difference between CCSP and SOURCE?"} CCSP and SOURCE serve the same population: frail elderly individuals age 65 or older and adults age 18 to 64 with physical disabilities who meet nursing facility level of care. The key difference is that SOURCE adds enhanced care coordination through an enrolled primary care physician. A SOURCE care coordinator works closely with the PCP to manage Medicaid services, Medicare services where applicable, and community resources. SOURCE is particularly useful for individuals with complex medical needs who benefit from integrated primary care plus community supports. :: ::accordion-item{title="Can my spouse be paid as my personal care worker?"} In CCSP, SOURCE, and ICWP, the answer is generally no. Spouses are excluded from paid caregiving under these waivers. In NOW and COMP, spouses CAN be paid as Live-In Family Caregivers when they live with the participant. The IDD waivers' Live-In Family Caregiver option recognizes the often-lifetime caregiving role that spouses sometimes play for partners with intellectual or developmental disabilities. :: ::accordion-item{title="What is Structured Family Caregiving?"} Structured Family Caregiving is a flexibility within CCSP and SOURCE that allows a family caregiver (typically an adult child or other adult relative who lives with or provides primary care for the participant) to receive a monthly stipend through a state-contracted vendor. The stipend is tiered (Tier 1, Tier 2, or Tier 3) based on functional assessment and reflects the intensity of care needed. A care coach from the contracted agency provides monthly visits, caregiving support, and care plan oversight. :: ::accordion-item{title="How does Electronic Visit Verification work?"} The 21st Century Cures Act of 2016 requires Electronic Visit Verification for every Medicaid-funded personal care services visit and home health care services visit. Georgia uses Tellus (part of HHAeXchange) as the state EVV data aggregator with Sandata as an alternate. Caregivers verify each visit using one of three methods: a mobile app on a smartphone with GPS verification, telephony from the participant's home phone, or a fixed visit verification device in the home. The system captures six required data elements: who provided service, who received service, what service, where, when service started, and when service ended. :: ::accordion-item{title="What is self-direction and how do I enroll?"} Self-direction is a service delivery model that lets you control your own personal care services. You have employer authority over your workers (hiring, scheduling, supervising, firing) and may have budget authority over an authorized cash allotment. A financial management service handles payroll, taxes, and workers compensation on your behalf. You remain the common law employer but the FMS handles the administrative employer functions. Self-direction is available in CCSP, ICWP, NOW, and COMP. To enroll, ask your care coordinator at your waiver enrollment or at your annual reassessment. :: ::accordion-item{title="Can I be paid to care for my adult child with intellectual disability?"} Yes, under NOW and COMP through the Live-In Family Caregiver option, if you live with your adult child. You are paid for caregiving hours that exceed typical parental obligation for an adult child. A financial management service handles payroll and tax withholding. Because you live in the same home as your child and receive Medicaid waiver payments, the IRS Notice 2014-7 difficulty of care exclusion typically applies and the Medicaid waiver payments are excludable from your federal income tax. Talk to a tax professional to confirm. :: ::accordion-item{title="How long is the waitlist for NOW and COMP?"} NOW waitlists are typically several years for non-crisis applicants. COMP waitlists are even longer, often 5 to 10 years or more. Crisis priority can move an applicant up the list for situations involving caregiver death, family crisis, abuse, neglect, or institutional placement risk. The state has worked to reduce the waitlists through state budget appropriations and federal funding but waitlists remain a major access barrier. Register early through the Division of Developmental Disabilities Regional Field Office. :: ::accordion-item{title="What is the difference between personal care services and home health?"} Personal care services are non-clinical support with activities of daily living (bathing, dressing, transfers, eating, ambulation, continence) and instrumental activities of daily living (meal preparation, light housekeeping, laundry, shopping, medication reminders). A personal care worker is not a nurse or therapist. Home health is a Medicare and Medicaid benefit covering skilled services from a registered nurse, physical therapist, occupational therapist, speech therapist, medical social worker, or home health aide. Home health is typically intermittent (a few visits per week) and tied to a homebound status. The two benefits complement each other and can be received simultaneously when both are medically necessary. :: ::accordion-item{title="Can a personal care worker give medications?"} No. Personal care workers can only ASSIST with medications (reminding, prompting, opening containers, handing medication to the participant) but not ADMINISTER medications. Medication administration is a skilled nursing function. However, the Georgia Board of Nursing's RN Delegation Rule permits a registered nurse to delegate certain health-related tasks to a personal care worker after assessment, training, and competency verification. Delegated tasks may include vital signs measurement, medication assistance, simple wound care, glucometer use, and ostomy care. The RN retains professional responsibility for the delegated task. :: ::accordion-item{title="What happens if my personal care hours are reduced?"} You have appeal rights under 42 CFR 431.200 et seq. The Medicaid Fair Hearing process requires advance written notice (typically at least 10 days before the change), opportunity for a hearing before an administrative law judge, the right to representation, the right to present evidence and cross-examine witnesses, and a written decision. If you file your appeal within 10 days of receiving the notice, aid paid pending appeal is available, meaning your services continue at the prior level until the hearing decision. Request a fair hearing in writing through your care coordinator or directly to DCH. :: ::accordion-item{title="How do I apply for CCSP, SOURCE, ICWP, NOW, or COMP?"} For CCSP or SOURCE, call the Aging and Disability Resource Connection at 1-866-552-4464. Your local Area Agency on Aging will complete a screening and arrange a functional assessment using the Determination of Need-Revised. For ICWP, contact your DCH regional office or call DCH Medicaid Member Services at 1-866-211-0950. For NOW or COMP, contact the Division of Developmental Disabilities Regional Field Office serving your area. Be prepared to provide medical documentation, functional information, and financial eligibility information. Apply early because NOW and COMP have long waitlists. :: ::

::cta{title="Need help understanding personal care services?" body="Call the numbers below to apply for a waiver, learn about self-direction, find a Structured Family Caregiving provider, or get help navigating the EVV system. Brevy.com publishes free Georgia Medicaid guides to help families plan."}

Georgia personal care services and waiver contacts:

  • DCH Medicaid Member Services: 1-866-211-0950
  • Aging and Disability Resource Connection (ADRC) / GeorgiaCares: 1-866-552-4464
  • Division of Aging Services (DAS) main line: 404-657-5258
  • Division of Developmental Disabilities (DDD): 404-657-2126
  • Department of Behavioral Health and Developmental Disabilities (DBHDD): 1-844-880-7642
  • Georgia Council on Developmental Disabilities: 404-657-2126
  • Georgia Advocacy Office: 1-800-537-2329
  • Money Follows the Person: through DCH Medicaid Member Services
  • Amerigroup Member Services: 1-800-600-4441
  • CareSource Member Services: 1-855-202-0729
  • Peach State Health Plan Member Services: 1-800-704-1484
  • Wellpoint Georgia Member Services: 1-800-300-8181
  • Tellus EVV Support (HHAeXchange): through provider portal
  • Sandata EVV Support: through provider portal

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For related coverage, see:

Disclaimer

This guide is provided by the Brevy Care Team as a public educational resource on Brevy.com. The information reflects Georgia Medicaid policy as of May 12, 2026 and is based on Section 1905(a)(24) of the Social Security Act, Section 1915(c) home and community-based services waiver authority, Section 1915(j) self-directed personal assistance services, Section 1915(k) Community First Choice, the 21st Century Cures Act Section 12006 Electronic Visit Verification mandate, Olmstead v. L.C., the HCBS Settings Rule, the FLSA Home Care Final Rule, IRS Notice 2014-7, and the Georgia Department of Community Health waiver provider manuals for CCSP, SOURCE, ICWP, NOW, and COMP. Eligibility determinations and service authorizations are made by the Georgia Department of Community Health, the Division of Aging Services, the Division of Developmental Disabilities, the Area Agencies on Aging, and the contracted Care Management Organizations based on individual circumstances. This guide is not legal, medical, or financial advice. For specific guidance about your situation contact the Georgia Aging and Disability Resource Connection at 1-866-552-4464 or DCH Medicaid Member Services at 1-866-211-0950.

BC

Brevy Care Team

Expert eldercare guidance from Brevy's team of healthcare professionals and researchers.