Here's a costly, common mistake: a new DSP starts delivering services before their file is complete, the agency bills for it, and an audit later disallows every one of those claims because a background check or required training wasn't on file on the date of service. A staff member is only billable once their qualifications are documented and current.
Use this checklist to gate that first billable shift. Nothing below should be "in progress" when the DSP starts delivering services.
Pre-employment & eligibility
- Application, resume, and verified references on file.
- Identity and work-authorization verification completed.
- All required background checks completed and cleared (criminal, and where applicable abuse/neglect registry, sex-offender registry, and exclusion-list checks).
- Confirmation the individual is not on any federal or state exclusion list (excluded individuals cannot be paid with Medicaid funds).
- Required licenses or certifications verified as current and authentic.
Required training (before first service)
- Agency policies, code of conduct, and mandatory-reporter responsibilities.
- HIPAA / privacy and security.
- Person-centered practices and rights of the individuals served.
- Abuse, neglect, and exploitation prevention and reporting.
- Incident reporting procedures and emergency response.
- Documentation standards and how to write a compliant service note.
- EVV clock-in/clock-out procedure (where applicable).
- Any service-specific or individual-specific training required by the plan of care (e.g., medication administration, transfers, behavior support plan).
Competency & sign-off
- Documented competency check for the specific services and supports the DSP will provide.
- Supervisor sign-off that the DSP is cleared to work independently.
- Date the DSP became eligible to deliver billable services is recorded.
Systems & access
- DSP set up in scheduling, documentation, and EVV systems with appropriate (least-privilege) access.
- Login tested and the DSP can complete a real note and an EVV check-in.
Record-keeping
- All of the above stored in the personnel file and retrievable on request.
- A renewal tracker is in place for anything that expires (background checks, certifications, annual training) so no one drifts out of compliance mid-employment.
The one rule to enforce
Do not schedule a new DSP for a billable service until the eligibility date is recorded and every "before first service" item is complete and on file.
Build that gate into your scheduling system if you can, it's far cheaper than disallowed claims and a corrective action plan.
This checklist provides general, federal/CMS-level guidance and is not legal advice. Specific background-check requirements, required training, competency standards, and timelines vary by state, waiver program, and service type, confirm your exact requirements with your state Medicaid agency and licensing authorities.