Can the same company do case management and home care in Georgia?
In Georgia’s CCSP and SOURCE manual, case management agencies may not also provide direct services in the same structure or operation. The manual also lists conflict-of-interest safeguards. Owners who want both usually need separate, clearly separated entities. Check the manual and ask DCH before you plan the structure.
This is one of the most important rules for owners who want to offer both.
What the July 2026 EDWP General Services manual says:
- A note in Section 605.1.26 states that case management agencies may not provide direct services in the same structure or operation.
- Section 605.1.27 requires conflict-of-interest safeguards.
- Case management agencies that add services or expand their area face audits and must submit a business plan for expansion.
- A client is free to choose a different agency than the one that referred them.
Why the rule exists: the person who plans and approves care should not be the same business that earns money from delivering it.
What owners do about it (a common practice, not a state instruction): they set up a separate legal entity for each role, with separate staff, books and supervision. That is a legal and compliance question, not a software one.
What to do now:
- Read Sections 605 and 607 of the manual.
- Ask DCH in writing how it defines "same structure or operation."
- Have your attorney review the setup before you apply.
Sources
- EDWP CCSP and SOURCE General Services manual, Q3 July 2026 · Georgia Medicaid (GAMMIS)
- Elderly and Disabled Waiver Program (long version) · Georgia DCH
Reviewed by Beth Bledsoe, Care Business Advisor®, 28 Oct 2026. Rules change. Confirm with your state Medicaid agency before you act.
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