Texas Home Care Agency 90-Day Post-Licensure Operations Checklist (2026)

Most Texas home care agency failures happen in the first year — and most first-year failures have operational roots that were planted in the first 90 days. Not insufficient clients. Not caregiver hiring. The most common cause is operational infrastructure that never got built correctly: MCO credentialing not started on time, EVV systems not configured before the first client, documentation practices that cannot withstand an HHSC survey, and billing workflows that have no one accountable for claim submission and denial follow-up.

This checklist covers the post-licensure window — starting from the day you receive your HCSSA license approval from HHSC and ending at 90 days. It assumes you have completed the application and pre-licensure steps covered in the How to Start a Home Care Agency in Texas guide. These are the operational tasks that turn a license into a functioning agency.

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The first two weeks set the foundation for your agency's operational timeline. These tasks cannot be done in parallel after the fact — each one has a cascade effect on everything that follows.

1. Submit STAR+PLUS MCO Credentialing Applications (Day 1–3)

This is the highest-priority action in your first week, and most new agency owners wait too long to start it.

Credentialing timelines are fixed at 60–120 days per MCO and run independently. Every day you delay submitting your first application is a day you push out the date you can bill STAR+PLUS claims. Submit to all applicable MCOs simultaneously — do not wait for one approval before starting the next.

Which MCOs to apply to depends on your service area:

• Houston (Harris County / Service Area 6): Amerigroup, Molina Healthcare, Superior Health Plan, UnitedHealthcare Community Plan, Aetna Better Health. Four to five separate applications with different portals, documentation requirements, and credentialing contacts.
• Dallas/Fort Worth (Service Area 7): Molina Healthcare, Superior Health Plan, UnitedHealthcare Community Plan. Three MCOs. Note: Superior Health Plan does not serve Tarrant County (Fort Worth) — if your agency operates in Tarrant County, your MCO set differs from Dallas County agencies.
• San Antonio (Bexar County / Service Area 8): Community First Health Plans, Molina Healthcare, Superior Health Plan.
• Austin (Travis County / Service Area 4): Amerigroup/Wellpoint, Superior Health Plan, UnitedHealthcare.

Each MCO application requires: HCSSA license copy, NPI number (Type II, organizational), CAQH profile (complete and attested), Certificate of Insurance meeting the MCO's minimums, W-9, and administrator credentials. See the Texas STAR+PLUS Payer Guide for a full credentialing requirements matrix by MCO.

2. Register for EVV Through HHAeXchange (Day 1–3)

Texas HHSC requires EVV for all STAR+PLUS Personal Assistance Services. Before you can accept a STAR+PLUS client, your agency must be registered in HHAeXchange and have a functioning EVV setup.

HHAeXchange registration for new providers goes through HHSC's EVV program office. The process takes 1–2 weeks from application submission to active provider status. Do this immediately — waiting until you have your first STAR+PLUS client is too late.

EVV registration checklist:

• Complete HHAeXchange new provider enrollment at hhaexchange.com/texas-providers
• Register your agency's NPI and HCSSA license number
• Select your EVV platform (HHAeXchange direct vs. integrated scheduling platform)
• Set up the caregiver mobile app or telephony option for visit verification
• Test a sample visit entry and confirm data flows to HHSC aggregator

3. Set Up Caregiver Hiring Infrastructure (Day 1–7)

Caregiver hiring is your first revenue-generating activity — agencies cannot serve clients without caregivers. But the compliance requirements around Texas HCSSA caregiver employment must be set up before your first hire, not discovered afterward.

Required for every caregiver hire:

• Texas DPS criminal background check (required before first client contact)
• OIG exclusion check (federal Medicaid exclusion list — must be checked at hire and monthly thereafter)
• I-9 employment eligibility verification
• HCSSA caregiver orientation (content must meet HHSC minimum hours — typically 8–16 hours depending on service type)
• Written employment agreement documenting caregiver classification, rate, and scheduling expectations
• Proof of required caregiver competencies (ADL assistance, emergency procedures)

Do not skip the monthly OIG exclusion check — employing a caregiver who appears on the OIG exclusion list is an HCSSA survey deficiency and can trigger MCO contract review.

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Once your MCO applications are in flight and EVV is registered, the next two weeks focus on building the operational infrastructure that will run your day-to-day.

4. Configure Your Scheduling System (Day 14–21)

Your scheduling system is the operational center of your agency — it connects caregiver availability, client service plans, visit verification, and billing. Configure it before your first client, not after.

Scheduling system setup checklist:

• Add all caregivers with their availability, qualifications, and authorized service types
• Create service plan templates for your primary service types (PAS, CDS if applicable)
• Connect scheduling software to HHAeXchange (if using an integrated platform)
• Test a complete shift creation → caregiver notification → check-in/check-out → EVV record cycle
• Set up supervisor access roles vs. administrator access roles

5. Establish Billing and Claims Workflow (Day 14–21)

Billing for STAR+PLUS claims requires a specific setup and workflow. Texas home care billing runs through TMHP (Texas Medicaid and Healthcare Partnership) for fee-for-service claims, and through each MCO's separate claims portal for managed care claims.

Billing infrastructure checklist:

• Register in TMHP (Texas Medicaid and Healthcare Partnership) at tmhp.com — required for any Medicaid billing
• Obtain clearinghouse access (Availity, Office Ally, or equivalent) for electronic claim submission
• Set up payer contracts in your billing system for each credentialed MCO (add these as credentialing approvals come in)
• Define your billing cycle: weekly, biweekly, or daily claim submission
• Establish a denial management workflow — who receives denial notices, how quickly are they worked, and what is the appeals process
• Designate a billing lead or back-office resource responsible for claim submission and AR follow-up

6. Draft Your Policies and Procedures Manual (Day 14–28)

HHSC requires every HCSSA-licensed agency to maintain a current policies and procedures manual that reflects the agency's actual operations and HHSC regulatory requirements. This document is reviewed at every annual survey.

If you purchased a policy template from a vendor (CarePolicy.US, Wise Caregiving, or similar), customize it to match your actual operations, service types, and service area before your first client. A template with generic placeholder text is an immediate survey deficiency.

P&P manual critical sections:

• Client rights and responsibilities (HCSSA-required language)
• Admission, discharge, and transfer criteria
• Emergency preparedness plan (specific to your service area — Houston and Dallas have different natural disaster protocols)
• Abuse, neglect, and exploitation reporting procedures
• EVV compliance procedures and exception management workflow
• Caregiver background check and OIG exclusion monitoring procedures
• Supervisory visit schedule and documentation requirements

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By Day 30, you should have your first private-pay clients active and your MCO credentialing applications under review. This phase focuses on building operational habits that will scale.

7. Accept First STAR+PLUS Clients (Days 45–60)

Your first MCO credentialing approval is likely to arrive in Days 45–75. When it does:

• Confirm you have received your MCO-specific provider number (this is different from your NPI)
• Add the MCO to your billing system with your specific provider contract rates
• Complete any MCO-specific onboarding requirements (orientation calls, compliance attestations)
• Verify that your EVV system maps correctly to this MCO's billing requirements
• Accept your first STAR+PLUS referral for this MCO

Do not accept a STAR+PLUS referral before receiving official written notice of credentialing approval with your provider number. MCO verbal "approvals" during the process are not binding.

8. Establish the EVV Exception Monitoring Routine (Days 30–60)

Every visit has the potential to generate an EVV exception — a mismatch between the scheduled visit and the verified visit record. An unresolved exception means the visit may not be reimbursed.

Set up a daily exception review routine from your first STAR+PLUS client onward:

• Review HHAeXchange exception queue daily (or at minimum every 2 days)
• Prioritize Category A exceptions (most severe — must be resolved within 72 hours)
• Document the reason for each exception in the HHAeXchange notes field
• Track your exception rate by exception type — this data is valuable for identifying systemic issues (e.g., a specific caregiver consistently forgetting to check out; a geographic area with GPS signal problems)

See the Texas EVV Exception Management Guide for a complete breakdown of all seven exception types and resolution workflows.

9. Maintain Caregiver File Compliance (Days 30–60)

Every caregiver file must be audit-ready at all times. Set up a compliance tracking process rather than a "fix it before a survey" approach.

Monthly caregiver compliance checklist:

• OIG exclusion check (must be done monthly for each active caregiver)
• Verify no background check recency issues (HHSC requires updated checks per guidelines)
• Confirm each active caregiver has a current orientation record on file
• Check that competency documentation for each service type is complete and signed

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By Day 60, you should have 1–3 MCO credentialing approvals, an active client census, and the core operational rhythm established. Month 3 focuses on building the documentation trail that will withstand your first HHSC survey.

10. Begin Supervisory Visit Documentation (Days 60–90)

HCSSA regulations require regular supervisory visits for active clients — the frequency depends on service type and client condition. These visits must be documented in the client record, not just logged in a supervisor's memory.

• Schedule supervisory visits for all active clients according to HHSC requirements
• Document each supervisory visit in the client file: date, findings, any changes to the service plan
• Complete supervisory visit documentation within 24 hours of the visit
• Flag any client condition changes that require a service plan update

11. Conduct Internal Pre-Survey Readiness Audit (Days 75–90)

Before your first HHSC survey (12–15 months from licensure), build the habit of quarterly self-audits. Your first self-audit at 90 days establishes your baseline — you will find gaps now, when you have time to fix them, rather than during an actual survey.

90-day audit checklist:

• Pull all caregiver files and verify each one has every required document
• Pull a sample of client care records and check for service plan currency, supervisory visit records, and client rights acknowledgment
• Export your EVV exception history and confirm no unresolved exceptions older than 30 days
• Review your P&P manual against the current HHSC HCSSA rules — correct any mismatches
• Verify the administrator's continuing education credits are on track for the annual cycle

12. Plan Back-Office Capacity for Growth (Days 75–90)

At 90 days, your credentialing approvals give you visibility into your capacity to grow your Medicaid census. Before you accept the next wave of STAR+PLUS referrals, assess whether your back-office capacity can support the additional volume.

Questions to answer at 90 days:

• Can your scheduler handle 15–20% more client-caregiver matches without adding scheduling errors?
• Is your daily EVV exception review keeping pace with your current census — if yes, what is the breakeven client count where it breaks down?
• How many hours per week is billing and claims work currently taking? At what census does this require a dedicated billing resource?
• Who handles MCO credentialing maintenance (CAQH re-attestation every 90 days, re-credentialing cycles) — is this person reliable?

Atlas Care provides trained remote back-office teams — schedulers, intake coordinators, billing specialists, and credentialing specialists — that work inside your existing tools and can be activated as your census grows. Contact us at atlascare.us to discuss what your agency needs at 90 days and beyond.

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The 90-day window establishes your operational foundation. What sustains a Texas HCSSA agency after that is a consistent compliance rhythm: monthly OIG checks, quarterly CAQH re-attestation, annual HCSSA survey preparation, and biennial license renewal.

Use the Texas Home Care Compliance Calendar 2026 to track the recurring obligations that run year-round. It covers CAQH re-attestation cycles, HCSSA survey windows, TMHP revalidation deadlines, and MCO credentialing renewal timelines by payer — organized month by month so nothing falls through the cracks.

The agencies that successfully scale past 30 clients in their first year share one operational characteristic: they built the administrative infrastructure in the first 90 days rather than trying to patch it together after growth started. The checklist above is not aspirational — it is the minimum operational baseline for a compliant, billable Texas STAR+PLUS home care agency.