Virginia has one significant structural advantage over most states: the CCC Plus Waiver has no waitlist. If someone qualifies, they get services. That creates a real referral pipeline. But the billing rules are specific — only whole hours, monthly rounding at 30 minutes, live-in caregivers need the UB modifier to exempt from EVV. And as of July 2025, one of the five Cardinal Care MCOs changed. Every agency with Molina contracts had to rebuild that relationship with Humana. Here is the full picture.
The Commonwealth Coordinated Care Plus (CCC Plus) Waiver is Virginia's 1915(c) HCBS waiver for individuals who need nursing facility level of care but choose — and are able — to remain in the community. Personal care, respite, companion services, assistive technology, environmental modifications, and more are covered. There is no waitlist. That is Virginia's defining advantage in the HCBS space. If an individual meets the clinical and financial criteria, they receive services.
The clinical requirement is nursing facility level of care, determined by the Long-Term Services and Supports (LTSS) Screening Team — either community or hospital screeners. Once screened and determined eligible, DMAS or its service authorization contractor must authorize all waiver services before any provider can be reimbursed. The MCO care coordinator manages authorizations for managed care members; DMAS's FFS service authorization contractor manages them for fee-for-service members.
Agency-directed personal care, respite care, private duty nursing, skilled respite, and companion services under CCC Plus are provided through licensed Home Care Organizations. The agency employs and directs the caregivers. Service authorization comes from the MCO care coordinator (for managed care members) or DMAS (for FFS members). Billing follows the whole-hours rule explained below.
Updated 2025 enrollment requirements: Agency-directed services now require the agency to meet specific criteria through the DMAS PRSS provider enrollment portal. Verify current requirements for your service type when enrolling or revalidating.
CCC Plus also supports consumer-directed personal care where the participant (or their designated employer of record) hires, supervises, and manages their own attendant. Eligible family members can be paid caregivers, including adult children, grandchildren, nieces/nephews, and siblings — but not spouses for personal care.
A Financial/Employer Agent (F/EA) handles payroll and tax functions for consumer-directed participants. The F/EA is separate from the home care agency. EVV for consumer-directed services uses Time4Care through PPL, the fiscal/employer agent for Virginia CCC Plus consumer-directed programs.
Cardinal Care Managed Care is Virginia's unified Medicaid managed care program, which merged the former CCC Plus and Medallion 4.0 programs effective January 1, 2023. All Virginia Medicaid members — including those in the CCC Plus Waiver — receive their services through Cardinal Care. As of July 1, 2025, Virginia Medicaid has five Cardinal Care MCOs:
Molina Healthcare exited Cardinal Care June 30, 2025. Former Molina members were auto-enrolled in Humana Healthy Horizons of Virginia effective July 1, 2025 with a 90-day window to switch. Humana offered a 60-day continuity of care period, allowing members to continue seeing current providers while Humana credentialing was completed. Any agency that had Molina contracts but didn't begin Humana credentialing promptly lost billing continuity for those members. Humana credentialing is currently processing in approximately 30 days. Contact: 1-844-881-4482.
Providers must be enrolled with DMAS through the PRSS (Provider Services Solution) portal AND contracted with each Cardinal Care MCO separately. Under federal rules, MCOs cannot pay claims to network providers who are not also enrolled in PRSS. Check your PRSS enrollment status, license information, and contact details regularly — outdated information in PRSS causes payment delays from both DMAS and the MCOs. Each MCO also has its own claims submission pathway: Anthem uses HealthKeepers processes, Humana uses Availity, Sentara uses Availity, United uses UHCprovider.com.
CCC Plus Waiver personal care services can only be billed in whole hours. You cannot bill 1.5 hours for a visit. But the rounding rule is monthly, not per visit:
If extra minutes across the calendar month total 30 or more: round up to the next whole hour.
If extra minutes total less than 30: round down. Bill the lower number.
This means you track cumulative minutes for each member across the month and apply the rounding at month-end. A member who consistently gets 1 hour 25 minutes per visit — 8 minutes short per visit — will accumulate those 8-minute shortfalls across the month. At the billing threshold, those fractions determine whether you round up or down for the month. Most billing errors on this rule come from agencies rounding per-visit rather than per-month.
The second rule that trips agencies is the UB modifier for live-in caregivers. When an agency employs a caregiver who lives in the same household as the client, DMAS exempts those visits from EVV requirements — because the caregiver is always present and traditional time/location verification doesn't apply. But to claim the exemption, the agency must use the UB modifier in association with the procedure code on the claim. Without the UB modifier, the claim will be evaluated against EVV records. No matching EVV record exists for the live-in visit. The claim denies.
| Scenario | Correct Action | What Happens If Wrong |
|---|---|---|
| Monthly minutes across all visits = 2 hrs 35 min | Bill 3 hours (35 min excess ≥ 30 min) | Billing 2 hours leaves authorized revenue on the table |
| Monthly minutes across all visits = 2 hrs 22 min | Bill 2 hours (22 min excess < 30 min) | Billing 3 hours is overbilling — triggers potential audit |
| Live-in caregiver provides personal care | Submit claim with UB modifier on the procedure code | Without UB: claim evaluated against missing EVV record, denied |
| Service authorization from MCO expires mid-month | Stop billing at expiration; request renewal through MCO care coordinator | Continuing to provide and bill without valid authorization creates overpayment liability |
Virginia home care agencies must hold a Home Care Organization (HCO) license from the Virginia Department of Health (VDH). Applications are submitted through VDH's Official Online Licensing (OLC) Portal. The triennial license fee is $1,500 — the renewal cycle is every three years.
HCO licensing requirements include staffing qualifications (RN clinical oversight), criminal background checks, policies and procedures documentation, and proof of adequate liability coverage. Updated enrollment requirements for certain CCC Plus service types took effect in 2025 — verify current DMAS requirements for your specific service categories through the PRSS portal.
Virginia uses a Provider Choice (open) EVV model. Agencies select their own EVV system as long as it captures the six federally required data elements and meets DMAS requirements. There is no single state-mandated EVV platform.
For Cardinal Care managed care members, the EVV data requirements are coordinated through the member's MCO — verify EVV expectations with each contracted MCO. For consumer-directed CCC Plus members, PPL uses Time4Care as the F/EA EVV solution.
The UB modifier exemption for live-in caregivers applies regardless of EVV system — it's a claims-level modifier that signals to DMAS or the MCO that the visit is exempt from EVV review.
The no-waitlist structure means there's no artificial cap on the size of your eligible client pool — unlike states where waiver waitlists of 5+ years limit the available population. But growth still depends on referral relationships with Cardinal Care MCO care coordinators, discharge planners, and LTSS screening teams who are the practical referral sources. Being credentialed with all five MCOs, maintaining strong documentation and EVV compliance, and building relationships with care coordinators in your service area are what actually drive growth in Virginia. The absence of a waitlist removes one ceiling. It doesn't replace the referral work.
Molina Healthcare exited Cardinal Care June 30, 2025. Former Molina members were auto-enrolled in Humana Healthy Horizons of Virginia. Agencies that had Molina contracts need to: complete Humana credentialing (processing in approximately 30 days currently, contact 1-844-881-4482 or [email protected] for LTSS services); verify that existing authorizations for affected members transferred to Humana; and understand Humana's specific prior authorization and claims submission processes (Humana uses Availity). Humana offered a 60-day continuity of care period for transition, but that window has passed for most agencies. If you haven't yet contracted with Humana, those members cannot be billed through your agency as an in-network provider.
Track total minutes delivered for each member across the calendar month. At month-end, convert to hours and apply the rounding: if the remaining minutes are 30 or more, round up to the next whole hour; if less than 30, round down. Bill the whole number. The most common error is rounding at the visit level rather than the monthly level — a caregiver who provides 1:25 on Monday and 1:25 on Wednesday hasn't hit 3 hours by Monday's visit. But by month-end with consistent visits, those 25-minute remainders may accumulate to 30+ and allow rounding up. Your billing system needs to track monthly totals per member, not just visit durations.
The UB modifier is a claim-level modifier appended to the procedure code on claims for visits delivered by live-in caregivers — caregivers who reside in the same household as the client receiving care. DMAS exempts live-in caregiver visits from EVV requirements because the caregiver's continuous presence in the home makes traditional time/location verification inapplicable. The UB modifier tells DMAS or the MCO that this claim is EVV-exempt. Without it, the claim is evaluated against an EVV record that doesn't exist, and it denies. Use the UB modifier on every claim line where a live-in aide provided the service.
Virginia agencies managing monthly whole-hours billing calculations across a large caseload, UB modifier tracking for live-in caregivers, authorization management across five MCOs (including the newly credentialed Humana relationship), and Provider Choice EVV compliance are managing significant operational precision requirements. CareBravo delivers scheduling, EVV compliance under the open model, billing with whole-hours rounding and UB modifier handling built in, and authorization tracking as completed work — so the billing team isn't manually calculating monthly hour totals per member at the end of every billing period.
Virginia's no-waitlist structure is a genuine competitive advantage — but capitalizing on it requires clean billing, strong MCO relationships across all five plans, and EVV compliance that doesn't create the denials that erode the revenue you're entitled to. The CareDrain Diagnostic shows exactly what your current gaps are costing you monthly.