Georgia Structured Family Caregiving is one of the most accessible pathways in Georgia for family caregivers to be paid through Medicaid. SFC is a service available under Georgia's CCSP (Community Care Services Program) and SOURCE (Service Options Using Resources in a Community Environment) Section 1915(c) HCBS waivers, administered by the Georgia Department of Community Health (DCH). SFC provides a daily stipend to family caregivers who live with the care recipient and provide substantial daily care. SFC stipends are typically treated as difficulty-of-care payments under IRS Notice 2014-7, which may exclude them from federal income tax in many circumstances. This guide explains the SFC program structure, Georgia-specific implementation, family relationship eligibility, application process, tax treatment, and how SFC compares to other Georgia family caregiver payment options.

## Why This Guide Exists

Family caregiver payment is one of the most-searched eldercare topics in America. Millions of family caregivers across the country provide unpaid care to aging parents, siblings, grandparents, and other relatives. The economic value of unpaid family caregiving is enormous, but it comes at substantial cost to family caregivers in lost wages, lost retirement savings, lost career advancement, and lost personal time. For many families, the question of whether and how a family caregiver can be paid through Medicaid or other programs is critical to making caregiving sustainable.

Structured Family Caregiving (SFC) is Georgia's most accessible pathway for family caregivers to be paid through Medicaid. SFC provides a daily stipend, training, agency support, and a clearly defined model that allows families to formalize a live-in family caregiving arrangement. SFC is available under Georgia's CCSP and SOURCE Section 1915(c) HCBS waivers and operates through contracted home care agencies that act as intermediaries.

This guide is necessary because SFC is widely available but poorly understood. Many Georgia families do not know that SFC exists, do not understand how it works, or assume it is more restrictive than it actually is. Other families have heard of SFC but are confused about how it compares to other family caregiver payment options such as NOW/COMP Participant-Directed Services, CCSP self-direction, VA programs, or private pay arrangements. This guide explains the SFC program structure, Georgia-specific implementation, eligibility criteria, application process, tax treatment, and comparison to other options so that Georgia families can make informed decisions about whether SFC is right for their situation.

What Is Structured Family Caregiving?

Core Concept

Structured Family Caregiving (SFC) is a Medicaid HCBS service model in which a family caregiver who lives with the care recipient receives a daily stipend for providing substantial daily care. The "structured" in Structured Family Caregiving refers to the structured oversight, training, documentation, and agency support that accompanies the family caregiving arrangement. SFC is not just a payment; it is a formalized care arrangement with case management, clinical support, training, and quality oversight.

SFC is distinct from other Medicaid family caregiver payment models in several important ways:

  1. Live-in requirement. SFC requires the family caregiver to live with the care recipient. This co-residence is foundational to the SFC model.

  2. Daily stipend. SFC pays a daily stipend rather than an hourly wage. The stipend reflects the substantial daily care the family caregiver provides, often approaching 24-hour-a-day responsibility.

  3. Agency intermediary. SFC operates through a home care agency that contracts with the state Medicaid agency. The agency provides case management, training, clinical support, and administrative services.

  4. Tax-favored treatment. SFC stipends are typically treated as difficulty-of-care payments under IRS Notice 2014-7, potentially excluding them from federal income tax.

  5. Substantial daily care requirement. The family caregiver must provide substantial daily care (typically ADL and IADL assistance throughout the day), not just occasional or part-time help.

How SFC Works in Practice

A typical SFC arrangement in Georgia works like this:

  1. The care recipient is enrolled in CCSP or SOURCE. This requires Georgia Medicaid eligibility, nursing facility level of care determination, and waiver slot availability.

  2. The care recipient and a family caregiver decide they want to pursue SFC. They identify a willing family member who can live with the care recipient and provide substantial daily care.

  3. They select an SFC-contracted home care agency. The case manager provides options. The family may have a choice among multiple agencies, each with somewhat different approaches.

  4. The agency conducts an initial assessment. A nurse or care manager from the agency visits the home, assesses the care recipient's needs, interviews the family caregiver, and develops a care plan.

  5. The family caregiver completes training. The agency provides training in personal care techniques, medication management (within state law limits), documentation, emergency response, and recognizing changes in the care recipient's condition.

  6. The family caregiver passes background check. Criminal background check and other required checks.

  7. SFC services begin. The family caregiver provides substantial daily care including ADL assistance, IADL assistance, supervision, medication management, meal preparation, transportation, and other tasks. The agency provides 24/7 phone support, periodic home visits, and ongoing case management.

  8. The family caregiver receives the daily stipend. Paid through the agency. Stipend amount depends on the care recipient's acuity tier.

  9. The agency provides ongoing quality oversight. Periodic home visits, care plan reviews, and beneficiary satisfaction monitoring.

  10. Documentation and Medicaid billing. The family caregiver documents care delivery (typically via paper logs, mobile app, or web portal). The agency aggregates documentation for Medicaid billing.

The Difficulty-of-Care Tax Treatment

One of the most attractive features of SFC is the federal tax treatment of the stipend under IRS Notice 2014-7.

IRS Notice 2014-7 clarifies that Medicaid HCBS payments to care providers who live with the care recipient may qualify as difficulty-of-care payments excludable from federal gross income under IRC Section 131. Section 131 was originally enacted to exclude qualified foster care payments from gross income. The notice extended this treatment to Medicaid HCBS payments meeting specific criteria.

For SFC stipends to qualify for the exclusion:

  1. The payment must be made under a state Medicaid waiver program. SFC qualifies because it operates under Section 1915(c) HCBS waivers (CCSP and SOURCE).

  2. The care provider must live in the care recipient's home. SFC's live-in requirement satisfies this.

  3. The care must be for an individual who would otherwise be in a foster care, adult foster care, or institutional setting. Care recipients on CCSP or SOURCE who meet nursing facility level of care meet this criterion.

When these conditions are met, the SFC stipend is excludable from federal gross income. The home care agency typically issues tax documentation (often 1099-MISC or W-2 depending on agency structure) but reports the payments as excludable difficulty-of-care payments.

The practical impact: When the difficulty-of-care exclusion applies, the after-tax value of the SFC stipend is materially higher than equivalent taxable wages from a traditional W-2 job. The exact uplift depends on the caregiver's federal marginal bracket and household tax situation; consult a tax professional to model the impact for your situation.

State income tax treatment may vary. Most states follow federal treatment, but families should consult tax professionals for state-specific guidance. SFC stipends are generally not subject to FICA (Social Security/Medicare) withholding because they are not wages from employment in the traditional sense.

Caveats:

  • The exclusion does not apply if the family caregiver does not live with the care recipient.
  • The exclusion does not apply to payments for care of individuals who do not qualify for the underlying Medicaid waiver.
  • Each family caregiver's specific tax situation should be reviewed with a qualified tax professional.
  • The IRS treats earned income differently from excluded difficulty-of-care payments for purposes of Earned Income Tax Credit and other credits. Family caregivers should understand these implications.

Family Relationship Eligibility

SFC family relationship eligibility generally includes:

Eligible:

  • Adult children of the care recipient
  • Adult grandchildren
  • Adult siblings
  • Adult in-law relatives (daughter-in-law, son-in-law, sister-in-law, brother-in-law)
  • Adult step-relatives (step-children, step-siblings)
  • Other adult blood relatives (aunts, uncles, cousins, etc.)
  • Adult foster family members in some circumstances

Generally NOT eligible:

  • Spouses (because spousal caregiving is considered an expected part of marriage and SFC is meant to supplement rather than replace it)
  • Legally responsible parents of minor children (parents are expected to provide care to their minor children)
  • Legal guardians who are not blood relatives in some circumstances

Specific family relationship rules in Georgia SFC should be confirmed with the contracted SFC agency, as exact eligibility can vary by agency contract and case manager interpretation.

Federal Authority for SFC

Section 1915(c) HCBS Waiver Authority

SFC operates as a service under Section 1915(c) HCBS waivers (codified at 42 USC 1396n(c)). Section 1915(c) authorizes states to provide home and community-based services to individuals who would otherwise require institutional care. States submit waiver applications to CMS that include:

  • The target population for the waiver.
  • The services covered under the waiver.
  • The cost-effectiveness analysis (waiver costs must not exceed institutional costs).
  • Quality assurance protocols.
  • Service definitions, provider qualifications, and rate methodology.

Georgia has included SFC as a service in its CCSP and SOURCE Section 1915(c) waiver applications, and CMS has approved these inclusions. The Section 1915(c) waiver authority provides the federal framework that allows SFC to operate as a Medicaid-covered service.

42 CFR Part 441 Regulations

42 CFR 441.300-.310 establishes general Section 1915(c) waiver regulations. Key requirements applicable to SFC include:

  • 42 CFR 441.301 (waiver application). Requires states to submit detailed waiver applications specifying services, populations, and operational parameters.
  • 42 CFR 441.302 (state assurances). Requires states to provide assurances regarding necessary safeguards, evaluation of need for institutional care, beneficiary choice between institutional and community care, and quality assurance.
  • 42 CFR 441.530 (HCBS settings rule). Requires that services be delivered in settings that are integrated into the broader community.

For SFC, the HCBS settings rule means that the care recipient's home (where the family caregiver lives) must support community integration. The home should not be operated as an institutional setting or otherwise isolating environment. The care recipient should have access to the broader community, choice in daily activities, privacy, and dignity.

IRS Notice 2014-7 Tax Framework

IRS Notice 2014-7 provides the federal tax framework for SFC stipends. The notice clarifies that Medicaid HCBS payments meeting the criteria described above may be excluded from federal gross income as difficulty-of-care payments under IRC Section 131.

The notice represents an important federal tax policy choice. By extending the difficulty-of-care exclusion to live-in Medicaid HCBS family caregivers, the IRS made SFC and similar arrangements substantially more attractive economically. Without this tax treatment, the after-tax value of SFC would be significantly lower, potentially making SFC unworkable for many families.

The notice has been criticized by some for its narrow scope (excluding non-live-in family caregivers, who provide substantial care but cannot claim the exclusion). Advocates have pushed for expanded tax exclusion for all Medicaid HCBS family caregiver payments, but Congress has not enacted such an expansion.

Fair Labor Standards Act Considerations

The Fair Labor Standards Act (FLSA) governs minimum wage and overtime for domestic service workers. In 2013, the Department of Labor revised the FLSA companionship services exemption to extend FLSA coverage to most direct care workers, including those providing companionship and personal care services. The revised rule took effect in 2015 after litigation.

For SFC, FLSA application can be complex:

  • Live-in domestic service workers are generally subject to FLSA minimum wage but not FLSA overtime (under specific exemptions).
  • SFC stipends are paid daily rather than hourly, which can create FLSA compliance complexity.
  • Some interpretations treat SFC family caregivers as independent contractors rather than employees, affecting FLSA application.
  • DCH and contracted agencies structure SFC arrangements to comply with applicable wage-and-hour law.

Family caregivers concerned about FLSA implications should discuss with their contracted agency and, if needed, consult employment law counsel.

Georgia SFC Implementation

Administering Agency

Georgia's SFC program is administered by the Department of Community Health (DCH). DCH:

  • Includes SFC as a service in the CCSP and SOURCE Section 1915(c) waiver applications submitted to CMS.
  • Contracts with home care agencies to deliver SFC services.
  • Sets SFC rate schedules and acuity tier methodology.
  • Provides program oversight including quality assurance and compliance monitoring.
  • Coordinates with CMS Region IV for waiver renewals and federal compliance.

DCH coordinates with:

Home Care Agency Partners

DCH contracts with several home care agencies to provide SFC services in Georgia. Specific agency contracts and availability change over time. Care recipients should contact DCH or their CCSP/SOURCE case manager for current options.

National providers active in Georgia SFC include:

  • Caregiver Homes / Seniorlink. One of the largest national SFC providers, operating in Georgia and several other states (Indiana, Massachusetts, Connecticut, Louisiana, and others). Caregiver Homes pioneered the structured family caregiving model and provides substantial training, technology platforms, and clinical support.

  • CareLinx by Sharecare. National caregiver services provider with SFC offerings. Provides care management, family caregiver support, and technology platforms.

  • Compass Health. Regional provider with SFC programs in Georgia and surrounding states.

  • Other DCH-contracted agencies. Various other home care agencies hold DCH contracts for SFC delivery.

Each contracted agency may have somewhat different approaches to:

  • Family caregiver training (online vs in-person, hours required, refresher schedules).
  • Documentation systems (paper logs, mobile apps, web portals).
  • Case management cadence (monthly home visits vs quarterly, in-person vs telehealth).
  • Clinical support (which licensed professionals provide oversight, how 24/7 support is structured).
  • Backup care arrangements (how the agency helps when the family caregiver is unavailable).

SFC Service Structure in Georgia

Georgia's SFC service typically includes the following components:

1. Daily stipend to family caregiver. Tiered by acuity level. Lower-acuity tiers carry lower daily stipends; higher-acuity tiers (for care recipients with advanced dementia or significant behavioral health needs) carry higher amounts. Specific rates vary by agency, contract year, and acuity assessment; pull the current DCH SFC fee schedule or your contracted agency's offer letter for exact figures.

Combined with the federal tax exclusion under IRS Notice 2014-7, the after-tax value can be substantially higher than equivalent taxable wages.

2. Care manager / coach support. Each SFC family caregiver is assigned a care manager (typically a nurse or social worker) who:

  • Conducts initial home assessment.
  • Develops care plan with family caregiver input.
  • Conducts ongoing home visits (typically monthly or quarterly).
  • Provides 24/7 phone support for clinical questions, emergencies, or other concerns.
  • Coordinates with the care recipient's medical providers.
  • Reviews and updates the care plan as the care recipient's needs change.

3. Caregiver training. The agency provides training in:

  • Personal care techniques (bathing, transferring, dressing, toileting).
  • Body mechanics and injury prevention (important for caregiver health).
  • Medication management within state law limits. Family caregivers in Georgia generally can assist with medication administration but cannot independently perform certain skilled medication tasks (which may require licensed nursing). Specific medication management roles depend on the care recipient's needs and state law.
  • Documentation requirements.
  • Emergency response.
  • Recognizing changes in the care recipient's condition (such as signs of infection, decompensation, or behavioral changes).
  • Self-care and caregiver burnout prevention.

4. Documentation and record-keeping. The family caregiver documents care delivery. Documentation systems vary by agency but typically include:

  • Daily care logs.
  • ADL/IADL completion documentation.
  • Medication administration records.
  • Notes on care recipient condition changes.
  • Time-and-attendance records (in some programs).

The agency aggregates documentation for Medicaid billing and quality oversight.

5. Backup care arrangement. SFC requires a backup plan for situations where the family caregiver is unavailable due to illness, emergency, respite, or planned absence. The agency:

  • Helps the family develop the backup plan.
  • May provide respite care directly through agency-employed workers.
  • Coordinates with adult day services, short-term assisted living, or other resources for longer absences.

6. Quality oversight. The agency conducts:

  • Periodic home visits (typically monthly or quarterly).
  • Care plan reviews.
  • Beneficiary satisfaction monitoring.
  • Critical incident reporting.
  • Compliance with DCH and CMS quality standards.

Care Recipient Eligibility

To receive SFC in Georgia, the care recipient must:

  1. Be enrolled in CCSP or SOURCE. This requires:

    • Georgia Medicaid eligibility. Including financial eligibility (the waiver income standard for CCSP/SOURCE is set under the special institutional income standard tied to the SSI Federal Benefit Rate; check current DCH eligibility guidance for the operative figure) and categorical eligibility.
    • Nursing facility level of care determination. Conducted by the Georgia DON-R (Determination of Need-Revised) assessment.
    • Waiver slot availability. CCSP and SOURCE share Elderly and Disabled Waiver Program (EDWP) capacity. CCSP commonly operates a waitlist when slot capacity is reached; SOURCE has historically had no waitlist. Contact your local Area Agency on Aging or DCH for current slot status.
  2. Have a family caregiver who can live with them. SFC requires co-residence, so the care recipient and family caregiver must share a household.

  3. Need substantial daily care. The care recipient must need substantial assistance with ADLs and IADLs that the family caregiver can provide.

  4. Choose SFC over other options. The care recipient can choose SFC instead of (or sometimes in combination with) other CCSP/SOURCE services. The case manager helps the care recipient understand the options.

Family Caregiver Qualifications

To serve as an SFC family caregiver in Georgia, the individual must:

  1. Have an eligible family relationship. As described above, adult children, adult grandchildren, adult siblings, in-laws, and other non-spouse adult relatives are typically eligible.

  2. Live with the care recipient. Co-residence is required.

  3. Pass background checks. Criminal background check and (where applicable) sex offender registry check, abuse registry check, and other required screenings.

  4. Complete training. The contracted agency provides initial training and ongoing training requirements.

  5. Demonstrate capacity to provide care. The agency assesses the family caregiver's physical and emotional capacity to provide substantial daily care. The agency may also assess potential for caregiver burnout and stress.

  6. Be willing to undergo ongoing oversight. The family caregiver must accept periodic home visits, care plan reviews, documentation requirements, and other quality oversight.

Application Process for Georgia SFC

The Georgia SFC application process typically involves the following steps:

Step 1: Care recipient applies for CCSP or SOURCE.

  • CCSP application. Contact the local Area Agency on Aging or DCH. The AAA conducts intake, screens for eligibility, and helps with the waiver application.
  • SOURCE application. Contact a SOURCE-contracted entity. SOURCE-contracted entities are specific provider organizations that coordinate care under SOURCE.
  • Application includes financial eligibility documentation, medical/functional assessment, and other required materials.

Step 2: Care recipient receives nursing facility level of care determination.

  • Conducted by the Georgia DON-R assessment.
  • Assessment evaluates the care recipient's ADL/IADL needs, cognitive status, and other functional measures.
  • Determination of nursing facility level of care is required for CCSP or SOURCE enrollment.

Step 3: Care recipient is approved for CCSP or SOURCE.

  • Approval requires financial eligibility, level of care determination, and waiver slot availability.
  • CCSP may have waiting lists for certain service slots. SOURCE enrollment depends on eligibility and SOURCE-contracted entity capacity.

Step 4: Care recipient and family caregiver decide to pursue SFC.

  • The case manager discusses available service options including SFC.
  • The family decides whether SFC is the right fit given the care recipient's needs and the family caregiver's situation.

Step 5: Select a contracted SFC agency.

  • The case manager provides options among DCH-contracted SFC agencies.
  • The family may choose among multiple agencies, comparing their approaches to training, support, documentation, and other features.

Step 6: Initial assessment by SFC agency.

  • Agency conducts home visit and assesses care recipient's needs.
  • Agency interviews family caregiver and assesses their capacity.
  • Agency develops initial care plan.

Step 7: Family caregiver completes background check and training.

  • Background check typically takes a few weeks.
  • Training requirements vary by agency but typically include initial intensive training plus ongoing refreshers.

Step 8: SFC services begin.

  • Once approved, the family caregiver begins providing care under the SFC arrangement.
  • The agency initiates stipend payments.
  • The agency provides ongoing case management and quality oversight.

The full process from initial application to SFC initiation typically takes 2-6 months depending on CCSP/SOURCE wait times, level of care determination scheduling, and agency capacity.

How SFC Compares to Other Family Caregiver Payment Options

SFC vs. NOW/COMP Participant-Directed Services

NOW (New Options Waiver) and COMP (Comprehensive Supports Waiver Program) are Section 1915(c) waivers administered by DBHDD for individuals with intellectual/developmental disabilities. Both include Participant-Directed Services as a self-direction option.

Key differences:

  • Population. SFC serves older adults and adults with physical disabilities through CCSP/SOURCE. NOW/COMP PDS serves the IDD population.
  • Administering agency. SFC is administered by DCH. NOW/COMP PDS is administered by DBHDD.
  • Live-in requirement. SFC requires the family caregiver to live with the care recipient. NOW/COMP PDS does not require co-residence.
  • Payment structure. SFC pays a daily stipend. NOW/COMP PDS pays hourly wages.
  • Family relationship eligibility. SFC allows non-spouse adult relatives. NOW/COMP PDS allows non-legally-responsible relatives (so parents of adult IDD participants typically cannot be paid because they serve as authorized representatives).
  • Self-direction features. SFC has limited self-direction features (the agency handles much of the administration). NOW/COMP PDS provides substantial self-direction including authority over hiring, firing, scheduling, and supervising workers.
  • Agency intermediary. SFC operates through SFC-contracted home care agencies. NOW/COMP PDS operates through DBHDD-contracted financial management services entities.

SFC vs. CCSP Limited Self-Direction

CCSP also offers a limited self-direction option for personal care services that is separate from SFC. Key differences:

  • Live-in requirement. SFC requires co-residence. CCSP limited self-direction does not.
  • Payment structure. SFC pays daily stipend. CCSP limited self-direction pays hourly wages.
  • Care intensity. SFC involves substantial 24-hour care. CCSP limited self-direction involves defined personal care hours based on assessment.
  • Tax treatment. SFC stipends may be excludable from federal income tax under IRS Notice 2014-7. CCSP self-direction wages are typically standard taxable wages.
  • Family caregiver model. SFC formalizes the live-in family caregiver. CCSP self-direction is a hired worker model (the worker can be family but is hired hourly).

SFC vs. Section 1915(j) Self-Direction (Not Adopted in Georgia)

If Georgia had adopted Section 1915(j) as a standalone State Plan authority (which it has not, as of 2026):

  • Population. Section 1915(j) could serve a broader population including individuals not currently eligible for CCSP/SOURCE.
  • Live-in requirement. Section 1915(j) does not require co-residence (though tax treatment under IRS Notice 2014-7 still requires it).
  • Payment structure. Section 1915(j) provides individualized budget authority and hourly wages.
  • Spousal payment. Some states' Section 1915(j) programs allow spousal payment. SFC generally does not.
  • Statewideness. Section 1915(j) requires statewide availability. SFC operates within CCSP/SOURCE.

For Georgia's federal HCBS authority context, see /medicaid/georgia/self-directed-services-1915j.

SFC vs. VA Family Caregiver Programs

For veterans, VA programs offer family caregiver payment options that may differ from or supplement SFC:

A veteran enrolled in Georgia Medicaid SFC might also qualify for VA programs depending on service-connected status and other factors. Coordination of VA and Medicaid benefits requires careful planning to avoid duplicate payment or eligibility complications.

SFC vs. Private Pay or Long-Term Care Insurance

Some long-term care insurance policies allow family caregiver payment. Private pay arrangements (where the family pays the caregiver directly) are always possible but lack Medicaid coverage. SFC provides Medicaid coverage for family caregiver payment without requiring private resources, making it accessible to families who do not have the means to private-pay.

Implications for Georgia Families

When SFC Is a Good Fit

SFC is well-suited for families where:

  1. The care recipient is eligible for CCSP or SOURCE. This requires meeting nursing facility level of care, financial eligibility for the waiver, and waiver slot availability.

  2. A non-spouse adult family member is willing and able to live with the care recipient. Co-residence is foundational to SFC.

  3. The family caregiver is willing to provide substantial daily care. SFC involves substantial 24-hour responsibility, not a part-time arrangement.

  4. The family caregiver does not have a full-time job outside the home. Because SFC caregiving is substantial daily care, it generally cannot be combined with full-time outside employment.

  5. The family is willing to accept agency case management and quality oversight. SFC includes substantial agency involvement, which families should embrace rather than resent.

  6. The family caregiver wants the tax-favored treatment of difficulty-of-care payments. SFC's IRS Notice 2014-7 treatment is a major economic advantage.

  7. The care recipient is comfortable having a live-in family caregiver. Some care recipients prefer agency-delivered care or a non-family caregiver for various reasons.

When SFC Is Not a Good Fit

SFC may not be the right option when:

  1. The care recipient does not meet nursing facility level of care. Sub-institutional needs are not covered by CCSP/SOURCE.

  2. The available family caregiver is a spouse. Spouses are generally not eligible for SFC.

  3. The family caregiver cannot live with the care recipient. Distance, family obligations, or personal preferences may make co-residence impossible.

  4. The family caregiver needs hourly wage rather than daily stipend. Some family caregivers prefer hourly compensation, especially if they want to work part-time outside the home and provide part-time care.

  5. The family wants full self-direction. Families who want substantial control over hiring, firing, scheduling, and individualized budget allocation should explore NOW/COMP PDS (for IDD) or seek other options.

  6. The care recipient is enrolled in NOW or COMP. NOW/COMP have Participant-Directed Services rather than SFC.

  7. The care recipient is enrolled in ICWP. ICWP does not include SFC.

  8. The family caregiver has caregiver burnout concerns. Live-in 24-hour caregiving is physically and emotionally demanding. Families should honestly assess whether the family caregiver has the capacity and support to sustain this arrangement.

Coordinating SFC with Other Resources

Families considering SFC should also explore:

  1. Medicare home health. Medicare covers limited home health for individuals meeting homebound criteria and needing skilled care. For dual-eligible beneficiaries (which most SOURCE participants are), Medicare home health can supplement SFC when skilled care needs arise.

  2. Veterans Affairs benefits. Veterans should explore VA Aid and Attendance, VA Veteran Directed Care, VA Program of Comprehensive Assistance for Family Caregivers, and other VA programs.

  3. Adult day services. Adult day services provide respite for the family caregiver and socialization/activities for the care recipient. ADS can be combined with SFC depending on the care plan.

  4. State and local respite resources. Georgia DAS Aging and Disability Resource Connection (1-866-552-4464) can help identify respite resources. Georgia has lifespan respite and other respite-focused programs.

  5. Family caregiver support programs. AARP Georgia, Georgia DAS, area agencies on aging, and other organizations offer caregiver support including counseling, training, peer support groups, and respite.

  6. Legal and financial planning. Family caregivers should consult elder law attorneys about Medicaid eligibility planning, asset protection, estate planning, and tax planning. The interaction of SFC stipend, IRS Notice 2014-7, EITC, Social Security earnings record, and other factors deserves professional review.

  7. Tax preparation. SFC families should work with tax professionals familiar with IRS Notice 2014-7. Improper tax reporting can result in unnecessary tax liability or audit risk.

Worked Examples

These worked examples illustrate how SFC works for Georgia families in different situations. All names and circumstances are illustrative.

Sarah 35 Atlanta: daughter SFC for mother

Sarah's mother Patricia (72) has multiple chronic conditions including diabetes, heart failure, and early-stage Alzheimer's disease. Patricia needs help with bathing, dressing, meal preparation, medication management, and supervision throughout the day. Patricia lives alone in her Atlanta home and increasingly cannot manage daily life independently. Sarah lives 30 minutes away and currently works full-time as a teacher's aide. Sarah is exhausted from constant trips to her mother's home for crises and emergencies.

Sarah's options under SFC:

  1. Apply for Patricia's CCSP enrollment. Patricia needs to be financially eligible (verify with DCH) and receive a nursing facility level of care determination via DON-R assessment.

  2. Move in with Patricia. Sarah and Patricia decide that Sarah will move into Patricia's home and become her live-in family caregiver. Sarah's husband and adult children support this decision.

  3. Select an SFC-contracted home care agency. Patricia's CCSP case manager provides options. Sarah and Patricia visit two agencies (Caregiver Homes and another contracted provider) before selecting.

  4. Initial assessment and care plan. The selected agency's nurse visits Patricia's home, assesses her needs, and works with Sarah to develop a care plan.

  5. Sarah completes background check and training. Initial intensive training plus ongoing weekly check-ins.

  6. SFC begins. Sarah leaves her teaching aide job. She receives a daily stipend at the tier assigned for Patricia's acuity. Under IRS Notice 2014-7, the stipend is excludable from federal income tax when conditions are met.

  7. Ongoing support. The agency conducts monthly home visits, provides 24/7 phone support, and helps Sarah navigate challenges as Patricia's condition progresses.

After two years on SFC, Sarah has stable income (excludable from federal tax under IRS Notice 2014-7, so the after-tax value materially exceeds equivalent taxable wages), Patricia has consistent quality care, and Sarah avoided burnout from the commuting-for-crises model. Sarah's tradeoffs: she gave up her teaching aide job and lost some career advancement, but she gained stable caregiver compensation, the ability to be with her mother, and the satisfaction of providing care herself rather than relying on agency workers.

Henry 50 Macon: brother SFC for sibling

Henry has multiple sclerosis with progressive disability. He needs help with bathing, dressing, transferring, meal preparation, medication management, and supervision. Henry's older brother William (62) is willing to move in and become his SFC caregiver. William is retired military with a pension and Social Security and does not need full-time wages but wants to contribute to Henry's care without depleting his own savings.

Henry's situation:

  1. Henry applies for CCSP. Henry meets nursing facility level of care criteria due to his MS. He is financially eligible (assets and income within waiver limits after appropriate planning).

  2. William moves in. William sells his small condo and moves into Henry's home in Macon. William has the physical capacity for caregiving despite being 62.

  3. SFC starts. William receives a mid-acuity SFC stipend. Specific tier daily amounts vary by contracted agency and assessment; pull the agency's offer letter for the exact figure. Under IRS Notice 2014-7, the stipend is excludable from federal income tax. Combined with William's military pension and Social Security, this provides comfortable income.

  4. Family relationship eligibility. William is Henry's brother (adult sibling), which is an eligible SFC relationship.

  5. Ongoing care. William provides substantial daily care. The SFC agency provides monthly home visits, training, and clinical support. William also benefits from the agency's caregiver wellness resources.

After 18 months, William has stable additional income (tax-favored), Henry has consistent quality care, and the brothers have grown closer through the caregiving relationship. William's tradeoff: he gave up his independence (his own home, his own routine) to live with Henry. The agency provides backup care for William's occasional respite (visits to his adult children, medical appointments).

Margaret 72 Savannah: grandmother as caregiver for grandson

Margaret's grandson Jacob (26) was injured in a car accident at age 22 and now has traumatic brain injury with cognitive disability and physical limitations. Jacob needs substantial daily care. Margaret (Jacob's paternal grandmother) is widowed, retired, and wants to provide care for her grandson.

Margaret and Jacob's situation:

  1. Jacob's eligibility. Jacob is enrolled in ICWP (Independent Care Waiver Program) for adults 21-64 with physical disabilities. However, ICWP does not include SFC. SFC is only available under CCSP and SOURCE.

  2. Alternative path: CCSP if eligible. Jacob may be assessed for CCSP eligibility. CCSP is generally for older adults but can serve adults under 65 with physical disabilities who meet nursing facility level of care. CCSP eligibility for younger adults depends on specific case-by-case determination.

  3. If CCSP eligible. Margaret could become Jacob's SFC caregiver as a grandmother (adult blood relative, non-spouse). Margaret moves in with Jacob in his Savannah apartment or Jacob moves in with Margaret.

  4. If not CCSP eligible. Jacob remains on ICWP and Margaret cannot receive SFC stipend. Alternative pathways: Margaret could explore Section 1915(j) (not adopted in Georgia), VA programs (not applicable since Jacob is not a veteran), or simply provide unpaid family caregiving with whatever support she can access.

The case illustrates that SFC has specific waiver-based eligibility requirements. Not every Georgia family with a need for live-in family caregiving can access SFC. Families in this situation may need to advocate for waiver flexibility, explore alternative authorities, or accept that SFC may not be available.

David 65 Augusta: adult son SFC for father with dementia

David's father Robert (85) has moderate-stage dementia and needs substantial supervision and assistance throughout the day. Robert lives in his Augusta home. David is recently retired from a 35-year career as an accountant and wants to provide care for his father. David's wife and adult children support this decision.

David's options under SFC:

  1. Robert's CCSP enrollment. Robert is enrolled in CCSP based on his dementia and ADL needs.

  2. David moves in. David moves into Robert's home. David's wife visits frequently and helps with respite.

  3. Higher-acuity stipend. Because Robert has dementia with significant supervision needs, the SFC agency assesses him at a higher acuity tier. David receives a higher-acuity SFC stipend; pull the agency offer letter for the exact daily rate. Under IRS Notice 2014-7, the stipend is excludable from federal income tax.

  4. Combination with David's retirement income. David is also drawing Social Security retirement benefits. SFC stipend is generally not "earned income" for SS earnings test purposes (because of the difficulty-of-care payment treatment). David should verify the specific interaction with his tax and benefits advisor.

  5. Ongoing care. David provides substantial daily care including supervision, ADL assistance, medication reminders, and behavioral support. The SFC agency provides ongoing case management. As Robert's dementia progresses, the agency may help David coordinate with hospice or other end-of-life resources.

After 14 months, David is providing high-quality dementia care while receiving tax-favored stipend. David's tradeoff: he gave up the active retirement he had planned (travel, hobbies, time with grandchildren) to live with his father. But David finds the caregiving meaningful and appreciates being able to honor his father's wishes to remain at home.

Linda 45 Athens: daughter-in-law SFC

Linda's mother-in-law Frances (78) has Parkinson's disease and needs substantial daily care. Frances's husband Robert (78) has his own health issues and cannot provide all the care Frances needs. Linda is married to Frances's son David. Linda and David live in Athens; Frances and Robert live nearby. Linda is willing to become Frances's SFC caregiver.

Linda's situation:

  1. Family relationship eligibility. Linda is Frances's daughter-in-law (in-law relative, non-spouse). This is generally an eligible SFC relationship.

  2. Frances's CCSP enrollment. Frances meets nursing facility level of care and is financially eligible.

  3. Living arrangement. Linda moves in with Frances and Robert (Frances and Robert's home is larger and Frances cannot easily move). David visits frequently. Robert (Frances's husband) lives in the home but is not Frances's SFC caregiver (because spouses are not eligible).

  4. Mid-acuity stipend. Linda receives a mid-acuity SFC stipend; pull the agency offer letter for the exact daily and annualized figure. Under IRS Notice 2014-7, this is excludable from federal income tax.

  5. Ongoing care. Linda provides substantial daily care. Robert assists where he can but is not the primary caregiver. The SFC agency provides case management, training, and support.

  6. Family complexity. This arrangement requires careful navigation of family dynamics. Linda is living with her in-laws and providing care while Frances's husband Robert is present. Communication, boundaries, and respect for all parties are critical.

After 12 months, the arrangement is working well for Frances (who has consistent quality care from a family member), Linda (who receives tax-favored stipend), Robert (who has help with his wife's care), and David (who knows his mother is well cared for). The SFC agency has helped the family navigate periodic tensions through case management support.

Robert 80 Columbus: shopping for SFC home care agency

Robert (80) has chronic obstructive pulmonary disease, congestive heart failure, and early dementia. He needs substantial daily care. His daughter Karen (52) is willing to be his SFC caregiver. Karen lives across town from Robert and plans to move in with him. Robert wants to choose carefully among SFC-contracted home care agencies.

Robert and Karen's process:

  1. CCSP enrollment. Robert is enrolled in CCSP at a higher acuity tier based on his multiple conditions.

  2. Agency options. Robert's CCSP case manager provides three SFC-contracted home care agencies operating in Columbus. Each agency has somewhat different approaches.

  3. Agency interviews. Robert and Karen schedule introductory visits with each agency. They ask about:

    • Training requirements and structure.
    • Documentation systems (paper logs vs mobile app).
    • Case management cadence and approach.
    • 24/7 support availability and response time.
    • Stipend payment timing and method.
    • Backup care arrangements.
    • Other family caregivers' experiences with the agency.
  4. Selection. Robert and Karen select an agency that uses a mobile app for documentation (Karen is comfortable with technology and finds this less burdensome than paper logs), provides monthly in-person home visits plus weekly phone check-ins, and has a strong reputation for caregiver support.

  5. Karen moves in. Karen rents out her own home (providing some additional income) and moves in with Robert.

  6. SFC begins. Karen receives a higher-acuity SFC stipend; pull the agency offer letter for the exact daily and annualized figure (tax-excludable under IRS Notice 2014-7).

This worked example illustrates that SFC includes meaningful agency choice in Georgia. Families should not just accept the first agency offered; they should compare options and select the agency that best fits their preferences and needs.

Frequently Asked Questions

Frequently Asked Questions

Structured Family Caregiving (SFC) is a Medicaid HCBS service model in which a family caregiver who lives with the care recipient receives a daily stipend for providing substantial daily care. SFC operates through home care agency intermediaries that provide case management, training, and administrative support. SFC is available in Georgia under the CCSP and SOURCE Section 1915(c) HCBS waivers. SFC stipends are typically treated as difficulty-of-care payments under IRS Notice 2014-7 and may be excludable from federal income tax.

No. SFC is available under CCSP and SOURCE Section 1915(c) HCBS waivers. SFC is not available under ICWP (Independent Care Waiver Program), NOW (New Options Waiver), COMP (Comprehensive Supports Waiver Program), or as part of the State Plan personal care benefit. The IDD population on NOW or COMP has access to Participant-Directed Services rather than SFC.

SFC family caregiver eligibility generally includes adult children, adult grandchildren, adult siblings, in-laws (daughter-in-law, son-in-law, sister-in-law, brother-in-law), step-relatives, and other non-spouse adult relatives. Spouses are generally NOT eligible because spousal caregiving is considered an expected part of marriage. Legally responsible parents of minor children are generally not eligible. Specific eligibility should be confirmed with the contracted SFC agency.

Yes. Co-residence is foundational to SFC. The family caregiver must live with the care recipient. If you cannot live with the care recipient, you cannot receive SFC stipend, though you may be eligible for other family caregiver payment options such as CCSP limited self-direction (hourly wages, no live-in requirement) or NOW/COMP Participant-Directed Services (for IDD population).

SFC stipends are tiered by acuity level: lower-acuity tiers carry lower daily stipends, and higher-acuity tiers (advanced dementia, significant behavioral health needs, complex medical needs) carry higher amounts. Specific daily rates vary by agency, contract year, and care recipient assessment. Pull the current DCH SFC fee schedule or your contracted agency's offer letter for exact figures. Under IRS Notice 2014-7, these stipends are typically excludable from federal income tax, substantially increasing the after-tax value.

Under IRS Notice 2014-7, SFC stipends paid to live-in family caregivers under Medicaid HCBS waivers are typically treated as difficulty-of-care payments excludable from federal gross income under IRC Section 131. The home care agency typically issues tax documentation (1099-MISC or W-2 depending on agency structure) but reports payments as excludable. Families should consult tax professionals for specific guidance. State income tax treatment may vary. SFC stipends are generally not subject to FICA withholding.

Generally no. Spouses are generally not eligible for SFC because spousal caregiving is considered an expected part of marriage. SFC is intended to supplement rather than replace family caregiving expected of spouses. If your spouse needs to be paid as your caregiver, alternative pathways include VA programs (if applicable), private pay, long-term care insurance, or seeking states that have adopted Section 1915(j) with spousal payment provisions (Georgia has not adopted Section 1915(j) as a standalone authority).

The application process: (1) Apply for CCSP or SOURCE through your local Area Agency on Aging (for CCSP) or SOURCE-contracted entity. (2) Receive nursing facility level of care determination via DON-R assessment. (3) Once enrolled in CCSP or SOURCE, discuss SFC with your case manager. (4) Select a contracted SFC home care agency. (5) Complete initial agency assessment, background check, and training. (6) SFC services begin. The full process typically takes 2-6 months.

DCH contracts with multiple home care agencies for SFC delivery. National providers active in Georgia include Caregiver Homes / Seniorlink, CareLinx by Sharecare, Compass Health, and others. Specific agency contracts and availability change over time. Contact DCH or your CCSP/SOURCE case manager for current options.

The SFC agency provides: (1) Initial assessment and care plan development. (2) Family caregiver training. (3) Background check coordination. (4) Ongoing case management including periodic home visits (typically monthly or quarterly). (5) 24/7 phone support for clinical questions and emergencies. (6) Documentation systems and Medicaid billing. (7) Quality oversight. (8) Backup care arrangements when the family caregiver is unavailable. (9) Coordination with the care recipient's medical providers.

SFC involves substantial daily care, typically approaching 24-hour responsibility. Most SFC family caregivers do not have full-time outside employment. Limited part-time work may be possible if the care recipient's care needs can still be met (e.g., with brief absences and backup care). Discuss with the SFC agency and case manager.

SFC requires a backup plan for situations where the family caregiver is unavailable. The agency helps develop the backup plan. The agency may provide respite care through agency-employed workers, or coordinate with adult day services, short-term assisted living, or other resources. Respite is critical to preventing caregiver burnout. Families should plan for and use respite proactively.

Brief comparison:

  • SFC. Live-in family caregiver, daily stipend, tax-favored treatment, CCSP/SOURCE only.
  • CCSP limited self-direction. No live-in requirement, hourly wages, standard tax treatment, CCSP only.
  • NOW/COMP Participant-Directed Services. No live-in requirement, hourly wages, standard tax treatment, IDD population only.
  • VA programs. Various, for veterans, different structures.
  • Private pay or LTC insurance. Various, depends on resources.

The right option depends on the care recipient's eligibility, family relationship, living arrangement, and other factors.

Yes, if eligibility conditions are met. Your parent must be enrolled in CCSP or SOURCE (which requires Georgia Medicaid eligibility and nursing facility level of care). You must be eligible as a family caregiver (adult child is an eligible relationship). You must live with your parent. You must provide substantial daily care. Dementia care often qualifies for higher acuity tiers, resulting in higher stipend amounts. Many SFC families care for parents with dementia.

SFC stipends excluded under IRS Notice 2014-7 are generally not "earned income" for Social Security purposes. This means SFC stipends typically do not affect Social Security earnings test (for those drawing benefits before full retirement age) and typically do not contribute to your Social Security earnings record. The specific interaction with Social Security depends on your individual circumstances. Consult a tax and benefits advisor.

The care recipient's acuity level can be reassessed if their condition changes. Higher acuity may result in higher stipend tier. The SFC agency provides ongoing case management to respond to changes. As care needs intensify, the family caregiver may need additional respite, training, or coordinated care (e.g., hospice). The agency helps coordinate.

You can discontinue SFC at any time. If you discontinue, the care recipient continues to receive CCSP/SOURCE services but through agency-delivered care rather than SFC. The transition should be coordinated with the case manager and SFC agency to ensure continuity of care. SFC participation is voluntary throughout.

Documentation requirements vary by agency but typically include: daily care logs, ADL/IADL completion records, medication administration notes, condition change observations, and time-and-attendance records (in some programs). The agency provides systems (paper, mobile app, or web portal) for documentation. Accurate documentation supports Medicaid billing compliance.

In many cases yes. SFC stipend is generally not "earned income" so it typically does not disqualify you from means-tested benefits in the same way wages would. Specific interactions depend on the benefit program. Consult a benefits counselor at DAS Aging and Disability Resource Connection or other benefits navigator.

Contact: DCH Medicaid Member Services (1-866-211-0950), DAS Aging and Disability Resource Connection (1-866-552-4464), your local Area Agency on Aging (for CCSP), or a SOURCE-contracted entity (for SOURCE). For tax questions about IRS Notice 2014-7, consult a tax professional. Brevy provides general information at brevy.com and is not a substitute for case management, legal advice, or tax advice.

Final Notes for Georgia Families

Structured Family Caregiving (SFC) is one of the most accessible and economically attractive pathways in Georgia for family caregivers to be paid through Medicaid. SFC formalizes the live-in family caregiving arrangement that many families already provide informally, adds payment, training, and oversight, and benefits from favorable federal tax treatment under IRS Notice 2014-7. For families where a non-spouse adult relative can live with the care recipient and provide substantial daily care, SFC can transform an unsustainable family caregiving situation into a viable long-term arrangement.

Georgia's SFC operates under the CCSP and SOURCE Section 1915(c) HCBS waivers through contracted home care agencies that provide case management, training, and administrative support. SFC stipends are tiered by acuity level; pull the current DCH SFC fee schedule or contracted agency offer letter for the operative daily rate. Under IRS Notice 2014-7, these stipends are typically excludable from federal income tax, substantially increasing the after-tax value.

SFC has limits. It requires the care recipient to be eligible for CCSP or SOURCE (nursing facility level of care, financial eligibility). It requires the family caregiver to live with the care recipient. It generally excludes spouses (and parents of minors). It requires substantial daily care, not just occasional help. It includes agency oversight that some families find supportive and others find intrusive. It is not full self-direction; the agency intermediary handles much of the administration.

For Georgia families considering SFC, the key questions are: (1) Is the care recipient eligible for CCSP or SOURCE? (2) Is there a non-spouse adult family member who can live with the care recipient? (3) Is the family caregiver willing and able to provide substantial daily care? (4) Does the family want the structured agency support that SFC includes? If yes to all four, SFC is worth pursuing.

Brevy is a digital ally helping Georgia families understand SFC and related family caregiver payment options. Brevy publishes guides at brevy.com to help families navigate Medicaid, Medicare, VA benefits, caregiving, and senior care. Brevy does not provide legal, tax, or financial advice. For specific guidance on your situation, including eligibility, application, tax treatment, and benefit coordination, consult Georgia DCH, DAS, the contracted SFC agency, tax professionals, elder law attorneys, and other qualified professionals.

Get Help With Structured Family Caregiving in Georgia

If you are a Georgia family considering Structured Family Caregiving, these resources can help you understand SFC and apply for the program.

  • DCH Medicaid Member Services. General Medicaid questions including CCSP and SOURCE. Phone: 1-866-211-0950.
  • DAS Aging and Disability Resource Connection. Aging and disability information, CCSP intake, caregiver support. Phone: 1-866-552-4464.
  • DCH HCBS Waiver Unit. Information on CCSP, SOURCE, and other HCBS waivers.
  • DCH CCSP Office. Direct information on CCSP and SFC.
  • DCH SOURCE Office. Direct information on SOURCE and SFC.
  • DFCS Customer Service. General Medicaid eligibility. Phone: 1-877-423-4746.
  • Georgia Gateway. Online portal for Medicaid applications and renewals.
  • AARP Georgia. Caregiver resources, advocacy, and support. Phone: 1-866-295-7283.
  • Georgia Long-Term Care Ombudsman. Advocacy for residents and beneficiaries. Phone: 1-866-552-4464.
  • Atlanta Regional Commission Area Agency on Aging. Local aging services in the Atlanta region. Other AAAs serve other regions.
  • Georgia Legal Services Program. Free legal help for income-eligible older adults including Medicaid appeals. Phone: 1-800-498-9469.
  • 211 Georgia. General resource referrals.
  • IRS Notice 2014-7 information. For federal tax treatment of difficulty-of-care payments. Consult a qualified tax professional for guidance specific to your situation.
  • Caregiver Homes / Seniorlink. National SFC provider operating in Georgia. Contact through DCH-provided agency lists.
  • CareLinx by Sharecare. National caregiver services provider with SFC offerings.

Find personalized help navigating Georgia at brevy.com.

BC

Brevy Care Team

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