Page posted: 8/26/24

Page reviewed:

Page updated: 8/25/25

Legal authority

Minn. Stat. §256B.85, subd. 5, Minn. Stat. §256B.0659

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.

Similarities

In both PCA and CFSS:

Differences

For people using PCA at the time of their assessment, the lead agency can only conduct remote assessments if the person is on a waiver.

For people using CFSS at the time of their assessment, the lead agency can conduct remote assessments in certain circumstances, regardless of whether the person is on a waiver. For more information, refer to CBSM – Assessment applicability and timelines.

Definitions

MnCHOICES Assessment: A tool to determine eligibility for CFSS. For more information, refer to CBSM – MnCHOICES.

Legacy assessment: A paper-based assessment. Some lead agencies have not fully transitioned to MnCHOICES and use CFSS Assessment, DHS-6893A. A certified assessor or a public health nurse completes the legacy assessment. Lead agencies must have DHS’ approval to use the paper-based legacy assessment.

The MnCHOICES assessment and DHS-6893A use the same criteria and formula to determine eligibility for PCA/CFSS.

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.

Process

Effective Oct. 1, 2024, all assessments are for CFSS services. If the lead agency conducted the assessment before Oct. 1, 2024, and enters the service agreement on or after Oct. 1, 2024, they will enter a PCA service agreement.

A person interested in accessing CFSS services must receive an assessment to determine their need for services through the following process:

1. The person requests an assessment from the responsible lead agency.

2. The lead agency schedules and conducts the assessment (refer to CBSM – Assessment applicability and timelines).

3. The lead agency authorizes services based on the results of the assessment.

4. The PCA/CFSS provider agency (PCA and CFSS agency model) or the financial management services (FMS) provider (CFSS budget model) requests a reassessment at least 60 days before the end of the person’s service agreement (refer to CFSS Manual – Reassessment for PCA/CFSS services).

For a more detailed overview of the process, refer to CFSS Manual – Overview of the PCA and CFSS process.

People age 65 and older enrolled in a managed care organization (MCO)

If a person is age 65 or older and enrolled in an MCO, the MCO follows its own process for assessment and service authorization.

Person’s responsibilities

The person is responsible to provide accurate and complete information during the assessment.

Lead agency’s responsibilities

Effective Oct. 1, 2024, the lead agency is responsible to:

1. Make arrangements to complete an in-person assessment in one of the following locations:

2. Conduct an assessment within 20 business days of receiving the request that:

3. Enter the service agreement into MMIS or the MCO’s authorization system with:

For MMIS instructions, refer to DSD MMIS Reference Guide – Type B service agreement for PCA/CFSS.

4. Provide all the following information to people:

Note: Lead agencies can print documents for people who cannot access content electronically.

5. Send CFSS eligibility results within 10 business days to the:

6. Review the service delivery plan from the consultation services provider within established timeframes and approve or deny it. For timeline information, refer to CBSM – Support planning for LTSS.

If the lead agency approves the CFSS service delivery plan, they must:

If the lead agency denies the CFSS service delivery plan, they must follow the requirements described on CBSM – Notice of action.

For more information, refer to CFSS Policy Manual – CFSS service delivery plan development and approval process.

7. Follow the appropriate instructions below based on the person’s circumstances to authorize CFSS services the person selects:

Examples of authorization to avoid gap in services

State plan

The person’s six-month PCA authorization is for Jan. 1, 2025, through June 30, 2025. After approving the person’s CFSS service delivery plan, the county/tribal nation enters a new service agreement for July 1, 2025, through Dec. 31, 2025, with:

Waiver/AC

The person’s six-month PCA authorization is for Jan. 1, 2025, through June 30, 2025. After approving the person’s CFSS service delivery plan, the county/tribal nation updates the existing service agreement with lines for July 1, 2025, through Dec. 31, 2025, with:

Temporary start of service for up to 45 days

If a person not currently using PCA or CFSS services has an immediate need to begin services, the lead agency can conduct a telephone assessment for a temporary start of CFSS services. For more information about that process, refer to CFSS Manual – 45-day temporary start of CFSS services.

Temporary increase to an existing service agreement for up to 45 days

If a person currently using PCA or CFSS has a temporary change in condition that requires more support, the lead agency can conduct a telephone assessment for a temporary increase. For more information about that process, refer to CFSS Manual – 45-day temporary increase of PCA/CFSS services.

Lead agency instructions for people who need additional time to complete the transition from PCA to CFSS

Lead agencies must use the following instructions to avoid a gap in services for people who need additional time to complete the transition from PCA to CFSS. Lead agencies can enter six additional months of PCA services for a person who already has a six-month PCA service agreement if the person meets at least one of the following criteria:

Note: People using CFSS through Alternative Care (AC) must transition to CFSS by March 31, 2026. All other people must transition to CFSS by Sept. 30, 2026.

Instructions for people who had their first CFSS assessment after Oct. 1, 2024, and are not due for a reassessment

People who are not on a waiver/AC and not enrolled in an MCO

The county/tribal nation must enter a new service agreement with a start date immediately following the end date of the person’s existing six-month service agreement. The new six-month service agreement must include the following lines:

People who are on a waiver/AC and not enrolled in an MCO

The county/tribal nation must add two new lines to the person’s existing service agreement. The two new lines must have a start date immediately after the end date of the existing lines. The two new lines must include:

The county/tribal nation does not need to enter a new consultation services line, but they may need to update the number of units and the end date of the existing consultation services line if it does not match the end date of the new PCA lines.

People enrolled in an MCO

The MCO follows its own processes and procedures.

Instructions for reassessments that happen between Oct. 1, 2025, and March 31, 2026

People who are not on a waiver/AC and not enrolled in an MCO

The county/tribal nation conducts the person’s reassessment between Oct. 1, 2025, and March 31, 2026. If the person has not yet transitioned to CFSS, the county/tribal nation must enter a new service agreement with a start date immediately following the end date of the person’s existing service agreement. The new six-month service agreement must include the following lines:

People who are on a waiver and not enrolled in an MCO

The county/tribal nation conducts the person’s reassessment between Oct. 1, 2025, and March 31, 2026. If the person has not yet transitioned to CFSS, the county/tribal nation must enter a new service agreement with a start date immediately following the end date of the person’s existing service agreement. The new service agreement must include:

People who are on AC

The county/tribal nation conducts the person’s reassessment between Oct. 1 and March 31, 2026. If the person has not yet transitioned to CFSS, the county/tribal nation must enter a new service agreement with a start date immediately following the end date of the person’s existing service agreement. The new service agreement must include:

People enrolled in an MCO

The MCO follows its own processes and procedures.

Instructions for reassessments that happen between April 1 and Sept. 30, 2026

People who are not on a waiver/AC and not enrolled in an MCO

The county/tribal nation conducts the person’s reassessment between April 1 and Sept. 30, 2026. If the person has not yet transitioned to CFSS, the county/tribal nation must enter a new service agreement with a start date immediately following the end date of the person’s existing service agreement. The new service agreement must end on Sept. 30, 2026, and include the following lines:

People who are on a waiver and not enrolled in an MCO

The county/tribal nation conducts the person’s reassessment between April 1 and Sept. 30, 2026. If the person has not yet transitioned to CFSS, the county/tribal nation must enter a new service agreement with a start date immediately following the end date of the person’s existing service agreement. The new service agreement must include:

People who are on AC

People using PCA through AC must transition to CFSS by March 31, 2026.

People who are enrolled in an MCO

The MCO follows its own processes and procedures.

Instructions for CSG services

For instructions for people who receive CSG services, refer to CBSM – CSG transition to CFSS.

Lead agency instructions for people who want to start CFSS before their PCA transition service agreement ends

If a person wants to start CFSS services before their PCA/CFSS transition service agreement ends, the lead agency must help the person end their PCA services and start their CFSS services early if all the following are true:

People who do not receive PCA/CFSS services through their MCO

People who are not on a waiver/AC

The county/tribal nation must:

1. Ask the existing PCA provider the date the person will stop using PCA and how many units they need to complete a coordinated transfer of care.
Note: This step is required even if the provider agency will also deliver CFSS services to the person.

2. Complete Lead Agency Addendum to CFSS Individual Service Delivery Plan, DHS-6893W based on the information they gathered in step 1.

3. Enter a new service agreement with:

4. Finalize the service agreement and manually route it to DHS. For more information, refer to DSD MMIS Reference Guide – Finalize a type B service agreement for PCA/CFSS.

DHS will end the existing service agreement and approve the new service agreement.

People who are on a waiver/AC

The county/tribal nation must update the person’s service agreement to end PCA services and start CFSS services if the person meets the four conditions described at the beginning of this section. The county/tribal nation must:

1. Ask the existing PCA provider the date the person will stop using PCA and how many units they need to complete a coordinated transfer of care.
Note: This step is required even if the provider agency will also deliver CFSS services to the person.

2. Complete Lead Agency Addendum to CFSS Individual Service Delivery Plan, DHS-6893W based on the information they gathered in step 1.

2. End the PCA service lines on the day the person will transition to CFSS.

3. Enter the person’s CFSS services on lines that start on the date after the last day the person will use PCA services.

People who receive PCA/CFSS services through their MCO

The MCO follows its own processes and procedures.

People who receive CSG services

For instructions for people who receive CSG services, refer to CBSM – CSG transition to CFSS.

PCA/CFSS provider agency’s responsibilities

For a person using PCA or the CFSS agency model (including a person using the CFSS agency model and purchasing goods/services), the PCA/CFSS provider agency is responsible to request a reassessment 60 days before the end of the person’s current service authorization.

FMS provider’s responsibilities

For a person on the CFSS budget model, the FMS provider is responsible to request a reassessment 60 days before the end of the person’s current service authorization.

If the FMS provider works with a person who uses the CFSS agency model and purchases goods/services, the FMS provider is not responsible to request a reassessment for that person.