How to start a home care agency in Washington, DC and reach your first client faster
The District has no unlicensed tier for home care. A nonmedical agency needs a DC Health Home Support Agency license, a staffed office inside DC, an RN, certified home health aides and five clients before its 90 day provisional license runs out. DC Medicaid personal care is a different path again: it requires a skilled Home Care Agency license, a Certificate of Need and Medicare certification, which is paused for new agencies. We put all of it in the right order for you.
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- Christine OchimasRN, LMFT, MBA
- All three care typesNonmedical, home health, hospice
- Written to District of Columbia rules22-B DCMR Chapter 99 (Home Support Agencies) or Chapter 39 (Home Care Agencies) and DHCF rules in 29 DCMR Chapter 50
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Updated November 2026 · Reviewed by Christine Ochimas, RN, LMFT, MBA
Answer two questions. See exactly what District of Columbia requires.
Personal care for DC Medicaid and EPD Waiver members
- State license
- A Home Support Agency license does not qualify. DHCF requires a DC Health Home Care Agency license (22-B DCMR Chapter 39) and Medicare enrollment as a home health agency (29 DCMR 5001)
- Who you deal with
- SHPDA, DC Health, CMS, DHCF and the DC Healthy Families health plans
- Must haves
- Certificate of Need, Home Care Agency license, Medicare certification (new enrollment paused by CMS from May 13, 2026), DHCF enrollment with a $50,000 surety bond, health plan contracts, EVV
- Realistic time to first client
- Longest path
Orientation for District of Columbia only. We confirm your exact path on the free call.
Three places new District of Columbia agencies lose months
Each one keeps you paying rent, insurance and payroll while no clients arrive.
Assuming nonmedical care needs no license
Owners who know Virginia or other states expect companion and personal care to be unlicensed. In the District, every agency giving personal care to a DC client needs a Home Support Agency license, an operating office inside DC and certified home health aides supervised by an RN. Serving clients first and licensing later is not an option.
What it costs: Months lost redoing the plan, plus enforcement risk for any client served without a license.
The five client test
DC Health issues a 90 day provisional license first. To earn the permanent license, the agency must reach at least five clients, tell DC Health, and pass an on site survey within that window. DC Health may renew the provisional license once for up to 90 more days, and it has written to agencies whose provisional licenses expired.
What it costs: A license that lapses after you have paid for the office, insurance, the RN and the application.
Planning on Medicaid with the wrong license
DC Medicaid pays for personal care aide services only through licensed home care agencies that are also enrolled in Medicare as home health agencies, with a $50,000 surety bond. A Home Support Agency cannot bill it. The skilled route needs a Certificate of Need first, and CMS paused new Medicare home health enrollment on May 13, 2026.
What it costs: A business plan built on Medicaid revenue that a nonmedical license can never collect.
What does a delay cost your agency?
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Home care vs home health vs hospice in District of Columbia
The three sound alike and are regulated differently. The one you choose decides your regulator, staffing, startup capital and timeline.
| Topic | Nonmedical home care | Home health (skilled) | Hospice |
|---|---|---|---|
| What your staff do | Personal care, companion and homemaker services, escort to appointments, help with medicines the client takes on their own | Skilled nursing and therapy, plus home health and personal care aide services | Palliative and supportive care for people who are terminally ill, and their families |
| State license | DC Health Home Support Agency license (22-B DCMR Chapter 99) | DC Health Home Care Agency license (22-B DCMR Chapter 39) | DC Health hospice license (D.C. Code § 44-501 et seq.) |
| Certificate of Need | Not listed in the Chapter 99 application; ask SHPDA for a determination if unsure | Yes, from SHPDA before licensure | Yes, from SHPDA |
| Main payers | Private pay, long term care insurance; not DC Medicaid personal care | Medicare, DC Medicaid (State Plan, EPD Waiver, DC Healthy Families plans), commercial insurance | Medicare hospice benefit, DC Medicaid, commercial insurance |
| Medicare | Not covered | Accreditation or state survey, then Medicare enrollment; check the CMS moratorium | Accreditation or state survey, then Medicare enrollment; check the CMS moratorium |
| Key staff | Full time director; RN director or full time RN Client Service Coordinator; certified home health aides | Director who is a physician, RN or health administrator with a year of supervisory experience; RNs, LPNs, therapists, aides | Administrator, physician medical director, RN leadership, interdisciplinary team |
| Startup capital | Moderate: a staffed DC office and RN from day one | Higher: Certificate of Need and clinical payroll before Medicare revenue | Highest: Certificate of Need and interdisciplinary team before revenue |
| Time to first client | Months, then 90 days to reach five clients | Longest: Certificate of Need, licensure, survey, enrollment | Longest: Certificate of Need, licensure, survey, enrollment |
Most new District owners start with a Home Support Agency because it needs no Certificate of Need, then decide whether to add skilled services. A Home Support Agency may not use the word "health" in its name, and a change of ownership means applying again as a new agency, so choose the name and structure with the long term plan in mind. We plan both paths from day one so your policies and hiring grow with you instead of being rewritten.
District of Columbia requirements at a glance
| Nonmedical home care license | Home Support Agency license from DC Health under 22-B DCMR Chapter 99, applied for online through the DC Health facilities licensing portal |
|---|---|
| Skilled home care and hospice | Home Care Agency license under 22-B DCMR Chapter 39; hospices are licensed under D.C. Code § 44-501 et seq. Both need a Certificate of Need from SHPDA. |
| Licensing agency | DC Health (Department of Health), Health Regulation and Licensing Administration; the Intermediate Care Facilities Division licenses home care and home support agencies |
| Office and census rules | An operating office in DC staffed at least eight hours each business day, a public website, and at least five clients to earn and renew a Home Support Agency license |
| Caregiver credential | Home health aides certified by the DC Board of Nursing (17 DCMR Chapter 93), supervised on site by an RN at least every 90 days |
| Background checks | Health-Care Facility Unlicensed Personnel Criminal Background Check Act (D.C. Code § 44-551 et seq.): criminal check before hire and a Nurse Aide Abuse Registry check |
| Medicaid agency | Department of Health Care Finance (DHCF): State Plan personal care aide services, the Elderly and Persons with Physical Disabilities (EPD) Waiver and DC Healthy Families health plans |
| Electronic visit verification | Required by DHCF for Medicaid personal care, skilled nursing and therapy visits; the District's Sandata system is free, or use an approved alternate system |
| Medicare (home health, hospice) | Accreditation or a DC Health survey, then Medicare enrollment; new enrollment paused nationwide by CMS from May 13, 2026 |
| Business registration | DLCP corporate registration and Basic Business License, Office of Tax and Revenue registration and Clean Hands, Certificate of Occupancy for the office |
Summary of District of Columbia requirements as of November 2026. Rules change; confirm with each agency before filing.
Step by step: launching a home care agency in District of Columbia
The order matters. The office lease, Certificate of Occupancy and Clean Hands come before the DC Health application, and your aide pipeline has to be ready before the provisional license starts, because the 90 day clock to reach five clients begins the day it is issued.
Form the business and register with the District
Register your LLC or corporation with DLCP, get an EIN, register with the Office of Tax and Revenue and obtain Clean Hands certification, then open employer accounts with DOES for unemployment insurance and Paid Family Leave contributions.
You do this; we give you the checklistDecide your license and payer mix
A Home Support Agency serves private pay clients with nonmedical personal care. If you want DC Medicaid personal care or skilled services, you need a Home Care Agency, a Certificate of Need and Medicare enrollment instead. Use the path finder above.
Decided on your free consultationLease a DC office and get the Certificate of Occupancy
Chapter 99 requires an operating office inside the District, staffed at least eight hours each business day, with posted hours. The Certificate of Occupancy must match the address on your application, and each office needs its own license. Pick a name without the word "health".
You do this; we specify what is requiredAppoint the director and RN, and buy insurance
Name a full time director who is a DC licensed RN, or a person with health services administration training and a year of supervisory experience plus a full time RN Client Service Coordinator. Buy $1 million malpractice coverage and $1 million / $2 million general liability, plus workers' compensation.
You do this; we specify what is requiredWrite policies to Chapter 99
Cover personnel, admissions, service agreements, RN assessments and service plans, client rights, complaints, incidents (reported to DC Health within 48 hours), infection control, billing, supervision and records. Build the public website Chapter 99 requires.
We write this for youApply to DC Health online
Submit the Home Support Agency application in the DC Health facilities licensing portal with the notarized application, ownership disclosure, Clean Hands form, Certificate of Good Standing, insurance, Certificate of Occupancy, director references and background check, formation documents and your policy manual, and pay the fees. DC Health then walks through the office.
We prepare the applicationBuild the aide pipeline
Hire home health aides certified by the DC Board of Nursing, run the criminal background check and Nurse Aide Abuse Registry search before hire, collect communicable disease screening from the six months before hire, check references and issue agency ID badges.
We set up the system and trackerReach five clients and pass the survey
During the 90 day provisional license, an RN assesses each client at home before services start and writes the service plan. Once you have five clients, notify DC Health and complete the on site survey to earn the 12 month license.
We get you ready for the survey
Home health aide certification and background checks
Both DC home care licenses use certified home health aides. Chapter 99 requires Home Support Agencies to employ aides qualified under 17 DCMR Chapter 93, which means certification by the DC Board of Nursing after a Board approved training program and competency examination. A rule proposed on September 11, 2026 would merge home health aides and nurse aides into one certified nurse aide credential.
- Aide certification: Aides need DC Board of Nursing home health aide certification: a Board approved training program using the Board's model curriculum, a certification examination and a Board criminal background check. DC licensed RNs and LPNs also qualify.
- Renewal education: To renew, aides complete 12 hours of continuing education each year (24 per renewal period), including HIV/AIDS and cultural competency topics, and show at least eight hours of paid nursing related work in the prior 24 months.
- Home Care Agency aides: Chapter 39 adds its own standard: 75 hours of classroom and supervised practical training, at least 16 of them practical, a competency evaluation, and 12 hours of training every year after the first.
- RN supervision: In a Home Support Agency, an RN supervises each aide on site at least every 90 days and reviews each service plan at least every 90 days. Chapter 39 agencies supervise skilled services every two weeks and other aide services every 62 days.
- Criminal background check: Before hire, every unlicensed worker who will have contact with clients needs a criminal background check through the Metropolitan Police Department, the U.S. Department of Justice or a private agency. Listed convictions in the past seven years bar employment.
- Nurse Aide Abuse Registry: No agency may employ an unlicensed person whose name appears on the District's Nurse Aide Abuse Registry.
- Health screening: Each worker must show screening for communicable diseases within the six months before hire, following CDC guidelines, plus acceptance or declination of the hepatitis vaccine.
- Credential changes ahead: Under the Certified Nurse Aide Amendment Act of 2024, DC Health has proposed converting home health aide certificates to a new CNA Dual certification that covers home and facility settings. The rule was still proposed in November 2026, so track it before you hire.
Six mistakes that slow District of Columbia agencies down
We look for every one of these in the first week of an engagement.
Opening without a DC Health license
- What it costs
- Serving even one DC client without a Home Support Agency license exposes you to enforcement and forces a restart.
- How we prevent it
- Your first call ends with your exact District path and the order to do it in.
Hiring uncertified caregivers
- What it costs
- Aides without DC Board of Nursing certification cannot provide personal care for a Home Support Agency, so shifts go unstaffed.
- How we prevent it
- A tracker that flags certification, renewal education, background checks and health screening for every aide.
Missing the five client deadline
- What it costs
- Without five clients and a passed survey by the end of the provisional period, the agency cannot earn its permanent license.
- How we prevent it
- We plan your first referral sources and marketing before the provisional license is issued.
Leasing the wrong office
- What it costs
- An office outside DC, or one whose Certificate of Occupancy does not match, stops the application.
- How we prevent it
- We check the office requirements, posted hours and website contents before you sign a lease.
Counting on Medicaid as a Home Support Agency
- What it costs
- DHCF only pays licensed home care agencies enrolled in Medicare, so the revenue never arrives.
- How we prevent it
- We map the license, Certificate of Need and Medicare steps Medicaid requires before you commit.
Putting "health" in the agency name
- What it costs
- Chapter 99 bars a Home Support Agency from using the word, so the name, website and filings must be redone.
- How we prevent it
- We review the name and business registration before you file anything.
In a free 30 minute call we confirm your District of Columbia path, flag the mistakes that apply to your plan, and give you a fixed price to handle the rest.
District of Columbia launch packages
Three fixed price packages, matched to the path you choose. Your exact price is quoted in writing after your free call, before any work starts.
Private pay launch
For nonmedical agencies serving families who pay privately.
- District of Columbia path and a dated launch plan
- Policy and procedure manual written to 22-B DCMR Chapter 99 (Home Support Agencies) or Chapter 39 (Home Care Agencies) and DHCF rules in 29 DCMR Chapter 50
- Service agreement, client rights and care plan forms
- Caregiver hiring and screening workflow
- Google Business Profile setup
EPD Waiver ready agency
Everything in Private pay launch, plus the Medicaid route.
- Policies aligned to EPD Waiver requirements
- Caregiver training and background check tracker
- Medicaid provider enrollment
- Credentialing packets for DHCF and the DC Healthy Families health plans (AmeriHealth Caritas DC and MedStar Family Choice DC)
- Survey and audit readiness
- District of Columbia city pages for local search
Home health and Medicare
For skilled home health. Hospice is scoped separately.
- Staffing and capital timeline
- Policies written to DC Health rules and the Medicare Conditions of Participation
- License application and inspection readiness
- Accreditation survey preparation
- Medicare and Medicaid enrollment support
Every package: one fixed price agreed in writing · you own 100% of your agency · no franchise fees or royalties.
On your own vs a franchise vs Lunaria
| Topic | On your own | Home care franchise | With Lunaria |
|---|---|---|---|
| Who owns the business | You | You, under the franchisor's brand and rules | You, 100% |
| Ongoing fees | None | Royalties and brand fees, usually a share of revenue | None. One fixed project fee |
| Knowing what District of Columbia requires | Pieced together from manuals and forums | A national playbook, adapted | Confirmed on your first call, then in writing |
| Policy manual | A template, often from another state | The franchisor's standard manual | Written to 22-B DCMR Chapter 99 (Home Support Agencies) or Chapter 39 (Home Care Agencies) and DHCF rules in 29 DCMR Chapter 50 |
| Medicaid credentialing | One application at a time | Varies by franchisor | Packets for DHCF and the DC Healthy Families health plans (AmeriHealth Caritas DC and MedStar Family Choice DC) prepared together |
| Your brand and marketing | Up to you | The franchisor's brand, with territory limits | Your brand, plus local search set up for you |
The District of Columbia home care startup checklist
Every District of Columbia step in order: business setup, your payer path, policies, caregiver screening and training, Medicaid enrollment and getting found. The items to start first are starred.
- Choose your license: Home Support Agency (nonmedical) or Home Care Agency (skilled, Medicaid, Medicare)
- Register your LLC or corporation with DLCP, with a name that does not use the word "health"
- Get an EIN, register with the Office of Tax and Revenue and obtain Clean Hands certification
- Open DOES employer accounts for unemployment insurance and Paid Family Leave
- Lease a DC office and get a Certificate of Occupancy in the agency's name
- and 14 more steps
Christine Ochimas, RN, LMFT, MBA
Christine founded Lunaria Care Consulting to give nurses and caregivers a direct route from "I want my own agency" to a compliant business with clients. She reads state requirements the way a reviewer does and writes policies the way a nurse would actually use them.
- We serve owners in all 50 states and DC, with a plan written for District of Columbia
- We help through enrollment and survey readiness, not just the application
- We tell you what we cannot promise: no one can guarantee a state or health plan decision
Have these ready for your consultation
- The care you want to provide and the clients you want to serve
- The District of Columbia cities or counties you plan to cover
- Where you are now: idea, business formed or already operating
- Who you expect to pay: families, EPD Waiver, Medicare
- Your target opening month and rough budget
No client or patient records. We never need them for a first call.
What it costs to start a home care agency in District of Columbia
| Item | Notes |
|---|---|
| Home Support Agency fees | Chapter 99 lists a $1,200 initial application processing fee and a $400 license fee, then annual renewal processing fees from $800 (1 to 50 clients) to $2,600 (351 or more clients), and a $100 late fee. Check current fees with DC Health. |
| Home Care Agency fees | Chapter 39 lists a $600 initial application fee and annual fees from $400 (1 to 150 patients) to $1,300 (1,251 or more). Check current fees with DC Health. |
| Certificate of Need (skilled care, hospice) | SHPDA's application fee is the greater of 3% of the proposed capital expenditure or $5,000, up to $300,000, plus the cost of the required newspaper notice. |
| Office and Certificate of Occupancy | A DC office staffed at least eight hours each business day, plus Department of Buildings and DLCP fees |
| Insurance | At least $1 million malpractice per incident and $1 million per occurrence / $2 million aggregate general liability for a Home Support Agency, plus workers' compensation |
| RN and director salaries | A full time director and an RN Client Service Coordinator if the director is not an RN, from the day the provisional license starts |
| Background checks and aide certification | Background check fees charged by the provider you use, plus training and certification costs for aides you sponsor |
| Medicaid surety bond (skilled route) | DHCF requires a continuous $50,000 surety bond for each enrolled office providing Medicaid personal care |
| Accreditation (home health, hospice) | Accrediting organization application and survey fees |
| Operating reserve | Covers rent, the RN and payroll while you build to five clients, or while the Certificate of Need and Medicare enrollment are pending |
Fees change. Confirm current amounts with each agency before budgeting.
How long it takes in District of Columbia
Months: business registrations and office, the DC Health application and walk through, then up to 90 days (180 with one renewal) to reach five clients and pass the survey.
Longest: Certificate of Need, Home Care Agency licensure, Medicare certification and enrollment, then DHCF enrollment and health plan contracts.
Longest: SHPDA suggests allowing six months for the Certificate of Need alone, then licensure, a certification survey and Medicare enrollment, subject to any CMS moratorium.
The District is one compact city, so agencies compete by neighborhood and ward rather than by county. Families search for care in places like Capitol Hill, Petworth, Anacostia and upper Northwest, and many adult children live in Maryland or Virginia suburbs while a parent stays in the city. Because Medicaid personal care runs only through Medicare certified home care agencies, a new Home Support Agency builds on private pay families, long term care insurance and referrals from hospitals and senior networks. A complete Google Business Profile and clear neighborhood pages match how people search.
Frequently asked questions
Do I need a license to start a nonmedical home care agency in DC?
Yes. An agency giving nonmedical personal care to clients in the District needs a Home Support Agency license from DC Health under 22-B DCMR Chapter 99. Agencies that also provide skilled services need a Home Care Agency license under Chapter 39.
How much does a DC Home Support Agency license cost?
Chapter 99 lists a $1,200 initial application processing fee and a $400 license fee. Annual renewal processing fees depend on census, from $800 for 1 to 50 clients up to $2,600 for 351 or more. Confirm current fees with DC Health before you apply.
What is the five client rule?
DC Health first issues a 90 day provisional license. To earn the 12 month license, a Home Support Agency must reach at least five clients, notify DC Health and pass an on site survey during that period. DC Health may renew the provisional license once for up to 90 days, and agencies need five clients to renew each year.
Do DC caregivers need to be certified?
Yes. Home Support Agencies must use home health aides certified by the DC Board of Nursing under 17 DCMR Chapter 93, and an RN must supervise them on site at least every 90 days. DC Health has proposed merging home health aide and nurse aide certification into one credential, so watch for the final rule.
Can a Home Support Agency bill DC Medicaid?
Not for personal care aide services. DHCF rules in 29 DCMR 5001 require Medicaid personal care providers to be licensed home care agencies that are also enrolled in Medicare as home health agencies, with a $50,000 surety bond. That path also needs a Certificate of Need.
Does DC require a Certificate of Need for home health or hospice?
Yes. DC Health's State Health Planning and Development Agency (SHPDA) requires a Certificate of Need to establish a new home health agency or hospice. You file a letter of intent, publish a notice, wait 60 days, then apply. SHPDA suggests allowing about six months to a decision.
Can a new home health agency enroll in Medicare right now?
CMS placed a nationwide moratorium on new Medicare enrollment of home health agencies and hospices from May 13, 2026, for six months unless extended, so it may have ended or been extended by the time you read this. DC Health has said it will not process initial hospice certification while it lasts. Check the CMS moratoria page before you plan around Medicare.
Is a franchise a better way to start a home care agency in DC?
A franchise gives you a brand and playbook in exchange for fees and ongoing royalties. Starting independently with Lunaria costs one fixed price, and you own 100% of your agency with no franchise fees or royalties.
How much does DC home care consulting cost?
Lunaria charges one fixed price per engagement, based on your path: a Home Support Agency, or a Home Care Agency with Medicaid and Medicare. You receive the price in writing after a free 30 minute consultation. There are no hourly charges.
Do you only work in the District?
No. Lunaria works with owners in all 50 states and DC, so you can add Maryland or Virginia with the same team.
Sources checked for this guide (37)
- DC Health Notice of Final Rulemaking, 22-B DCMR Chapter 99 Home Support Agencies (67 DCR 9476, August 7, 2020)
- DCRegs: 22-B DCMR 9904, License Fees (effective 8/7/2020, no later amendments listed)
- DCRegs: 22-B DCMR Chapter 39, Home Care Agencies (sections 3900 to 3919, 51 DCR 2876)
- DC Health Office of Health Facilities Licensing Portal (moratorium alerts, online applications since May 3, 2023)
- DC Health Home Support Agency application reference guide
- DC Health Home Care Agency application reference guide (lists Certificate of Need)
- DC Health Intermediate Care Facilities Division
- DC Health Home Support Agencies page and alerts
- DC Health Procedures to Obtain a License to Operate a Home Care Agency (revised November 2011)
- DC Health HCFD and ICFD Regulations Quick Reference Guide
- D.C. Code § 44-501, licensure definitions (home care agency, hospice)
- D.C. Code § 44-401, Certificate of Need definitions (home health agency, hospice)
- D.C. Code § 44-551 and § 44-552, unlicensed personnel criminal background checks
- DC Health Certificate of Need page (SHPDA)
- SHPDA Certificate of Need FAQs (February 2023)
- SHPDA Criteria and Standards, Home Health Services (2021)
- DCRegs: 17 DCMR Chapter 93, Home Health Aides (9304 certification, 9307 renewal, 9327 training programs) and proposed rulemaking of 9/11/2026 (73 DCR, Vol 73/37)
- D.C. Law 25-232, Certified Nurse Aide Amendment Act of 2024
- DC Health HHA renewal page
- DCRegs: 29 DCMR 5001, Medicaid PCA provider qualifications, and 5011, insurance and surety bond
- DHCF Medicaid Director Letter 22-02, EPD Waiver renewal effective February 7, 2022
- DHCF Transmittal 26-19, Managed Care Plan Transition (Wellpoint DC enrollees to AmeriHealth Caritas DC, August 1, 2026)
- DHCF Transmittal 21-45, EVV for personal care services
- DHCF Transmittal 22-38, EVV for skilled nursing, private duty nursing and therapy from January 1, 2023
- DHCF EVV FAQs (Sandata system, alternate EVV)
- DHCF Electronic Visit Verification page
- DLCP Business Resource Center: four steps to a Basic Business License
- DC Office of Paid Family Leave, information for employers
- D.C. Code § 32-531.02, paid sick and safe leave
- CMS Provider Enrollment Moratoria page (HHAs and hospices, May 13, 2026; last modified August 27, 2026)
- Federal Register 2026-09717: nationwide moratorium on Medicare enrollment of home health agencies
- Federal Register 2026-09718: nationwide moratorium on Medicare enrollment of hospices
- CMS accreditation and approved accrediting organizations
- CMS-855A Medicare enrollment application, institutional providers
- 42 CFR Part 484, home health Conditions of Participation (Cornell LII)
- 42 CFR Part 418, hospice care (Cornell LII)
- MedStar Family Choice DC policy 182.DC, Personal Care Assistant services (July 2025; plan policy, secondary)
This guide is general information and reflects District of Columbia requirements as we understood them in November 2026. Requirements change. Confirm current rules, fees and procedures with DC Health, the Department of Health Care Finance and CMS before filing. Lunaria Care Consulting provides professional consulting services and does not provide legal advice.
Other states: see all state guides. What we do: licensing, compliance, Medicaid enrollment and local search marketing.