How to start a home care agency in Minnesota during the moratorium.

Most guides on starting a home care business in Minnesota assume you can file a 245D application, wait for review, and open. That path is paused. Effective January 1, 2026, DHS stopped accepting new applications under Minn. Stat. ch. 245D, the licensing statute for home and community-based services, at both the basic and intensive support services levels. Applications that were pending were cancelled, not queued. Existing licensees cannot add new service lines to their licenses during the pause either.

DHS cited a 283% surge in applicants and a review backlog as the reason. The moratorium is expected to last roughly 24 months, through December 31, 2027. Nothing about that timeline is guaranteed, so treat it as planning input, not a promise. If you were partway through a 245D application, you are effectively starting over when applications reopen, and this guide is about what to do in the meantime. For the full detail, see our moratorium guide.

Enrolling as a PCA or CFSS agency remains open and is the most common entry point for new owners who want to serve waiver-adjacent populations without a 245D license. Two transition facts should shape any plan in this lane:

• Extended PCA cannot be received after September 30, 2026, so do not build a model that depends on it.
• The overall PCA/CSG-to-CFSS transition deadline was extended in May 2026 to September 30, 2027; people who miss the 2026 date may continue on standard state-plan PCA while transitioning.
• EVV applies here: 50% of billed visits from January 1, 2026, rising to 80% from July 1, 2026, with DHS corrective-action notices to sub-80% providers beginning October 2026.
• All EVV-required providers must enroll with HHAeXchange, the state aggregator, and submit all visit data through it.

Enter this lane planning for CFSS as the destination program and EVV as a day-one operating requirement, not a later cleanup project. Our CFSS transition guide and EVV requirements guide cover both in depth.

Whether you are working an exception angle or planning to apply when the moratorium lifts, the strongest position is a business that already runs like a licensed provider. Three areas matter most:

• Policies and procedures: draft the 245D policy set now. Consultant policy packages commonly sell for $850 to $1,280 (STAR Services is the best-known source), which is a reasonable benchmark for what a complete set costs on the open market. See our policies and procedures guide before buying.
• Leadership qualifications: 245D requires designated coordinator and designated manager roles, each with a statutory qualification ladder combining education and supervised experience (a degree plus fewer years, or no degree plus more direct-care years). Map yourself and any planned hires against the statute now, because experience takes calendar time you cannot compress later.
• Operating systems: EVV workflows, visit documentation, case notes, consents, and audit trails are easier to stand up before you have clients. An agency that can demonstrate working systems is more credible to a lead agency and faster through any future licensing review.
• A track record: running an MDH home care or CFSS operation cleanly for the duration of the moratorium is itself the best evidence you can put in front of a licensor or a county.

The moratorium is expected to end after December 31, 2027. Founders who spend the interim operating in an open lane and documenting well will be applying with evidence. Founders who spend it waiting will be applying with a binder.

ClientCentric is operations software for 245D and HCBS agencies: client records, scheduling, visit documentation with EVV workflows built for HHAeXchange, case notes with a locked lifecycle, consents with expiry, and append-only audit history, with migration included in onboarding. For a founder building systems before or alongside licensure, it means your documentation practices exist before your first audit does. It produces billing-ready EVV-verified hours and units; claim submission to MN-ITS and MCOs stays in your billing workflow. If you want a baseline of where you stand, start with the free 245D review readiness quiz or book a walkthrough.