Staying in Compliance in North Carolina Medicaid

A practical guide for North Carolina home care providers navigating PCS documentation, audits, and recent policy changes.

If you’re a Personal Care Services (PCS) provider in North Carolina, you already know that staying compliant with NC DHHS requirements isn’t optional — it’s the foundation of your agency.

One missed form, one outdated document, one overlooked portal upload can trigger a delayed claim or land your agency in an audit.

The good news: most compliance failures aren’t the result of bad intent. They’re the result of busy teams working with incomplete information.

Understanding the Landscape: What DHHS Is Looking For

NC Medicaid administers PCS through Clinical Coverage Policy 3L, and the state uses a third-party contractor, Acentra Health via the NCLIFTSS system, to manage assessments and provider compliance. Your primary portal for nearly everything PCS-related is QiRePort (www.qireport.net), and if your team isn’t fully comfortable in that system, compliance becomes an uphill battle.

NC Medicaid conducts quarterly compliance audits. Each quarter, QiRePort randomly selects 100 providers for review, covering both Supervisory Visit documentation and Aide Training documentation. You won’t always know in advance if you’re selected, which means your records need to be audit-ready every single day — not just when a letter arrives.

The Key Documents Every PCS Provider Must Have in Order

1. NC Medicaid 3136: Quality Improvement Attestation Form

This form must be submitted annually by December 31 for each National Provider Identifier (NPI) your agency holds. It attests that your agency is in compliance with Section 7.7 of Clinical Coverage Policy 3L, which governs your internal quality improvement program.

Where it goes: Uploaded directly to the QiRePort portal under your Provider Name/NPI. NC Medicaid uses QiRePort as the only database to verify this submission during audits — faxed or emailed copies will not count.

Common mistake: Agencies with multiple NPIs forget to submit a 3136 for each one. If you operate under more than one NPI, each requires its own annual attestation.

2. NC Medicaid 3085: Session Law 2013-306 PCS Training Attestation

This form is required if your agency serves beneficiaries who have been approved for additional/expanded hours under Session Law 2013-306. It confirms that your aides have completed the required additional training for individuals with degenerative memory conditions.

Where it goes: Also uploaded to QiRePort, and it only needs to be submitted once per provider. However, it must be on file before you begin serving beneficiaries approved for expanded hours.

Important note: Expanded hours require the attending physician to submit a Change of Status request. Your 3085 must already be on file in QiRePort by the time those hours are authorized.

3. DHB 3051: Request for Services Form

As of April 1, 2025, NC Medicaid will delay processing any PCS request submitted using an outdated version of the DHB 3051 form. Only the current version is accepted. If your team has a saved version from 2023 or earlier, replace it now.

Where to find the current version: The NCLIFTSS website at ncliftss.acentra.com. Check it periodically — forms do get updated.

Supervisory Visits: Don’t Let the 90-Day Clock Run Out

Clinical Coverage Policy 3L requires that an RN conduct supervisory visits for each beneficiary on your caseload. The standard is a 90-day supervisory visit cycle, with a 7-calendar day grace period allowed.

During an audit, NC Medicaid will request documentation of these visits. Your documentation must include:

Date of the supervisory visit
RN’s signature and credentials
Observations and any noted changes in the beneficiary’s condition
Confirmation that the care plan is being followed

If a beneficiary is selected during an audit and you are no longer serving them, you still must respond. Do not ignore the audit letter. Document that you are no longer the provider and return the letter with that information noted. Failure to respond — even for former clients — counts against your compliance record.

Aide Training Documentation: Get It Right from Day One

Aide training compliance is one of the most common failure points in NC Medicaid PCS audits. Here’s what auditors are looking for:

Training certificates or test completion records for each aide, including the employee’s full name and the date training was completed
Coverage of required topics (infection control, ADLs, safety procedures, etc.)
For beneficiaries with degenerative memory conditions: evidence of the additional specialized training required under Session Law 2013-306
The PCS Training Checklist must be signed by a Registered Nurse, with credentials included, unless the aide has been employed less than 6 months, in which case other qualified staff may conduct basic ADL training if proof of employment start date is provided

NC Medicaid does not provide standardized training documentation forms. Your agency creates its own — but every required element outlined in CCP 3L must be present. If any element is missing, the document is considered non-compliant.

The QiRePort Portal: Your Compliance Hub

If your agency is not actively using QiRePort, you are operating at significant risk. Here’s a quick checklist of what should be set up and active:

Your agency is enrolled in the Provider Interface at www.qireport.net
At least one staff member has administrative rights to upload documents
The NC Medicaid 3136 for each NPI has been uploaded for the current year
The NC Medicaid 3085 is uploaded if you serve beneficiaries with expanded hours
All service plans are documented and validated in QiRePort before claiming
You are checking QiRePort regularly for upcoming annual reassessment notifications

A reminder on billing: Prior approval for PCS hours is not granted until the service plan is entered into and validated through QiRePort’s Provider Interface. Billing before this step is complete creates claim problems and potential overpayment liability.

Recent Policy Changes to Know in 2025–2026

NC Medicaid has made several changes that affect PCS providers. Here’s a brief rundown:

Congregate Settings Rate Change (Effective January 1, 2025) Reimbursement for individuals in congregate settings shifted from 15-minute increments to a daily per diem rate. Providers bill one line per date of service using procedure code 99509. Claim lines spanning multiple dates or with a unit greater than one will deny.

Updated DHB 3051 Form (Effective April 1, 2025) Old form versions are no longer accepted. Update your intake workflow to ensure the current version is always in use.

EVV Requirements Ongoing Electronic Visit Verification remains a compliance requirement for NC PCS providers. Claims without required EVV data will deny. If you use an alternate EVV solution (not Sandata), you must be registered with NC DHHS via the alternate EVV registration form. Ensure your EVV data is validated before claims adjudication.

Building a Compliance-First Culture at Your Agency

Documentation and portal management are only as good as the team executing them. Here are a few practical steps to reduce compliance risk:

Assign a compliance owner. Someone on your team should own PCS compliance as a defined responsibility — not as an afterthought. This person monitors QiRePort, tracks annual deadlines, and serves as the point of contact when audit letters arrive.

Create a compliance calendar. Map out annual deadlines (3136 by December 31), 90-day supervisory visit cycles, reassessment notification windows, and form review dates. Put them somewhere the whole team can see.

Audit yourself before NC Medicaid does. Quarterly, pull a random sample of your own cases and review documentation the same way an auditor would. Are training certificates complete? Are supervisory visit records signed and dated? Are you using the current DHB 3051?

Respond to every audit letter, even for former clients. Ignoring letters — even when you no longer serve that beneficiary — creates a negative compliance record. Always respond in writing with documentation of your situation.

Stay connected to NCLIFTSS and NC Medicaid updates. Provider notices are published on both the NC Medicaid website and the NCLIFTSS site. Assign someone to check these regularly — changes to forms, deadlines, and billing rules are posted there before they take effect.

Bottom Line

NC DHHS PCS compliance isn’t complicated if you treat it as an ongoing system rather than a one-time checklist. The agencies that struggle with audits are usually the ones relying on memory and informal processes. The agencies that pass with flying colors are the ones that built structure around their documentation long before an auditor ever comes knocking.

Keep your QiRePort portal updated. Use current forms. Document every training and supervisory visit thoroughly. And when policy changes come — and they will — make sure someone on your team is reading those provider notices.

Your clients depend on you. Solid compliance practices protect your ability to serve them.