Georgia CCSP and SOURCE Waiver Compliance: What Agencies Need to Know in 2026

Georgia's two largest Home and Community-Based Services (HCBS) Medicaid waivers — CCSP and SOURCE — carry documentation and audit obligations that go well beyond standard home health billing. As enrollment in both programs grows, so does OIG and CMS scrutiny of how agencies document eligibility, service delivery, and caregiver qualifications. This guide walks through what agencies operating under either waiver need to have in place.

What Are CCSP and SOURCE, and How Do They Differ?

The Community Care Services Program (CCSP) is Georgia's original HCBS waiver, providing in-home and community-based services as an alternative to nursing facility placement for elderly and disabled Medicaid beneficiaries. SOURCE (Service Options Using Resources in a Community Environment) is a companion waiver that layers case management and enhanced primary care coordination on top of a similar HCBS service set, generally for a more medically complex population.

Both programs are administered by the Georgia Department of Community Health (DCH) and require participants to meet an institutional level-of-care determination — meaning they would otherwise qualify for nursing facility placement — before services can be authorized.

What Documentation Do Waiver Participants Require That Standard Home Health Doesn't?

• Plan of Care (POC) — a waiver-specific care plan authorized by a case manager, distinct from a standard home health plan of care, that specifies approved services, frequency, and duration.
• Service authorization — each waiver service line requires a specific unit authorization; delivering more units than authorized creates an overpayment exposure even if the care was clinically appropriate.
• Level-of-care redetermination — participants must be reassessed periodically (annually in most cases) to confirm they continue to meet the institutional level-of-care threshold; a lapsed redetermination puts every service delivered after the lapse date at risk.

How Does EVV Apply to Waiver Services?

Personal care and similar in-home waiver services are subject to the same Sandata EVV requirements as standard PCS billing. The added complexity for waiver agencies is alignment — EVV visit records must match not just the six required data points, but also the specific service authorization for that participant. A visit that's clean from an EVV standpoint but exceeds the authorized unit count for the billing period still creates exposure.

What Are the Common Audit Triggers for CCSP and SOURCE Agencies?

• Units billed in excess of the current service authorization
• Services delivered after a level-of-care redetermination has lapsed
• Plan of Care on file that doesn't match the services actually billed
• Caregiver qualification documentation (training, background check, licensure where applicable) missing or expired
• Self-directed or participant-directed service arrangements without documented employer-of-record and payroll compliance
• EVV exception rates significantly above the state average for the same service type

What Does Georgia DCH Expect From a Compliant Waiver Agency?

DCH's compliance expectation for waiver agencies centers on documentation that a reviewer can trace end-to-end: an active level-of-care determination, a current Plan of Care, a service authorization that matches what was billed, EVV records that match the authorization, and caregiver qualification files that are current. Agencies that can produce this chain for any given participant on request are in a materially stronger audit position than agencies that can only produce pieces of it.