Page reviewed:

Page updated: 9/11/25

Legal authority

Minn. Stat. §256B.85, subd. 10 and 13a

Comparison of PCA and CFSS

DHS is in the process of replacing PCA with CFSS. For more information about this transition, refer to CFSS Manual – Transition from PCA and CSG to CFSS.

Differences

PCA does not include financial management services (FMS). This page applies to CFSS only.

Definitions

Financial management services (FMS) provider: An organization that people use to help them with employer-related responsibilities and FMS tasks. DHS contracts with all FMS providers to provide these services and enrolls them as Minnesota Health Care Programs (MHCP) providers. For more information about the services, refer to CFSS Manual – FMS for CFSS.

Note: FMS providers also provide similar services to people using consumer directed community supports (CDCS). For information about those services, refer to CDCS Manual – FMS for CDCS.

Responsible party (RP)/participant’s representative: An individual who is age 18 or older and capable of directing care on behalf of a person receiving PCA/CFSS services when the person is assessed as unable to direct their own care. In PCA, this individual is called the RP. In CFSS, this individual is called the participant’s representative.

Note: All references to “representative” on this page refer to the participant’s representative, unless otherwise specified.

Applicability

The following people must choose an FMS provider:

People who use the CFSS agency model and do not purchase goods/services do not need to choose an FMS provider.

Overview

A person cannot bill the state directly for approved CFSS goods and services. The FMS provider submits claims and receives payments from the state on behalf of the person. These payments are used for approved goods and services through CFSS.

Multiple people must use the same FMS provider when all the following are true:

When there is a joint employer, all people associated with that joint employer must use the same FMS provider. Joint employment is determined by an FMS provider or other entity based on guidelines provided by the U.S. Department of Labor.

Provider standards and qualifications

DHS contracts with all FMS providers to provide FMS. DHS determines if FMS providers meet the qualifications through a request for proposal (RFP) process at a frequency determined by DHS. To view open RFPs, refer to DHS – Grants and RFPs.

An FMS provider must meet all of the following qualifications:

1. Successfully complete a readiness review before enrollment that is conducted by a person or organization that meets the qualifications required by the state.

2. Be a financially solvent organization.

3. Have all of the following:

Requirements to act as an agent of the person

FMS providers function as statewide vendor fiscal/employer agent (VF/EA) FMS organizations in accordance with Section 3504 of the Internal Revenue Service (IRS) Code and Revenue Procedure Code 2013-39, as applicable.

To provide fiscal agent services, the FMS provider must:

General responsibilities

FMS providers are responsible to:

For more information, refer to the sections below.

Disclose financial interests

An FMS provider who has any direct or indirect financial interest in the delivery of certain services to the person must disclose the nature of that relationship to the person in writing. These services include, but are not limited to:

The FMS provider must obtain a document signed by the person stating the person both:

Have an agreement with the person or their representative

An FMS provider must have a written agreement with the person or their representative that outlines roles and responsibilities of the FMS provider, the person/representative and the support workers. The agreement also should identify the FMS provider’s fees and outline the actions the FMS provider or person/representative will take if the agreement is not followed.

Help the person meet legal requirements for their CFSS workers

An FMS provider must help the person meet legal requirements for their CFSS workers.

Labor laws

An FMS provider must help the person follow all applicable local, state and federal labor laws, including but not limited to:

Service Employees International Union (SEIU) Healthcare Minnesota and Iowa collective bargaining agreement (CBA) terms

An FMS provider must help the person follow the SEIU CBA terms (refer to SEIU – Home care), including but not limited to:

For more information, refer to PCA Choice and FMS provider information.

Have the ability to submit background studies

An FMS provider must have the ability to submit background study requests to DHS on behalf of the person. The type and extent of background studies the FMS provider is required to facilitate are those that follow the requirements under Minn. Stat. Ch. 245C. For more information, refer to DHS – Background studies.

Person’s rights

The FMS provider must provide the person with a written copy of their rights, including:

The FMS provider must:

Billing

The FMS provider bills DHS or the managed care organization (MCO) for all goods and services the person uses, except:

Billing for required employer expenses

The FMS provider must bill for required employer expenses, including CFSS worker time when applicable. The FMS provider includes the costs to pay the CFSS worker for employment-related activities in a claim for covered personal care services the worker provided. For example, if a worker provided four hours (16 units) of personal care (T1019) services and spent two hours on a required employment-related activity, the FMS provider must:

Examples of required employer expenses include costs for:

Note: The FMS provider has additional billing responsibilities for worker classes. For more information, refer to CFSS Manual – CFSS worker training and supervision.

Documentation and reporting requirements

The FMS provider must maintain records to ensure a clear audit trail and track all CFSS spending, including:

The FMS provider also must:

For more information, refer to CFSS Manual – FMS documentation and reporting for CFSS.

Rates

FMS provider responsibilities

The FMS provider must:

DHS responsibilities

DHS may establish maximum FMS provider fees.

Limitations

The FMS provider cannot in any way:

Lead agencies cannot provide FMS.

The FMS provider may offer CFSS consultation services, CFSS provider agency services and contracted case management services, but they cannot provide these services to people who are using FMS from them.

The FMS provider cannot provide FMS to a person who lives in housing the FMS provider owns.

If the FMS provider offers training as part of their business, they cannot offer that training to the workers of a person they are serving.