The Florida Agency for Health Care Administration (AHCA) has confirmed that home health agencies enrolled as Provider Type 65, Specialty 221 may participate in and receive reimbursement through Florida’s Family Home Health Aide (FHHA) for medically fragile children program.

The clarification resolves a longstanding question concerning whether Medicaid Private Duty Nursing (PDN) Specialty providers without Medicare certification could bill for FHHA services.

In a written response provided to HCAF, AHCA identified Florida State Plan Amendment FL-24-0011 as the applicable federal authority. The amendment added FHHA services to Florida’s Medicaid State Plan and allows home health agencies to receive reimbursement for services provided by an eligible family member caring for a medically fragile child.

Provider Type 65, Specialty 221 Eligibility Confirmed

AHCA also pointed providers to Appendix C of the Florida Medicaid Provider Enrollment Policy, which addresses enrollment requirements for PDN specialty providers.

The policy provides that home health agencies furnishing only PDN services — or both PDN and FHHA services — are not required to maintain Medicare certification or an equivalent accreditation to enroll in Florida Medicaid. Without that certification or accreditation, an agency may not enroll under the home health agency specialty but may enroll under the PDN specialty.

Based on that policy and the applicable federal authorities, AHCA expressly confirmed that:

“A provider type 65 with a specialty of 221 may bill from the PDN fee schedule and the Family Home Health Aide fee schedule.”

Billing and service delivery must comply with the applicable service-specific requirements contained in Rule 59G-4.261, Florida Administrative Code.

What the State Plan Amendment Does

The Centers for Medicare & Medicaid Services (CMS) approved State Plan Amendment FL-24-0011 on October 15, 2025, with an effective date of October 1, 2024. The amendment updated Florida’s home health benefit to include services provided by FHHAs caring for medically fragile children.

The approved language requires the aide to be employed by an agency licensed under state law and supervised by a licensed registered nurse. It also specifies that FHHA services may not replace authorized PDN services or supplant other covered home health services.

AHCA explained that these services are authorized under the “other licensed practitioner” benefit in section 1905(a)(6) of the Social Security Act and 42 Code of Federal Regulations section 440.60. Services provided under this authority are not subject to the Medicare conditions of participation that otherwise apply to home health services furnished under 42 Code of Federal Regulations section 440.70.

What This Means for Providers

The confirmation establishes that an appropriately licensed and enrolled Provider Type 65, Specialty 221 agency may bill for both authorized PDN and FHHA services. Medicare certification or equivalent accreditation is not required when the agency enrolls through the PDN specialty and limits its services accordingly.

Participation is not automatic, however. Providers must continue to satisfy all applicable Medicaid enrollment, licensure, authorization, training, supervision, documentation, electronic visit verification, billing, and service-specific policy requirements.

Agencies interested in furnishing FHHA services should review their Florida Medicaid enrollment information, the Provider Enrollment Policy, and Rule 59G-4.261 to ensure that their operations meet all program requirements before submitting claims.

HCAF appreciates AHCA for providing the definitive clarification providers needed to move forward. HCAF will continue working with AHCA and its members to address implementation questions and support access to FHHA services for medically fragile children and their families.