EIDBI Update: DHS Provisional Licensure & Consultant Disclosure

As part of our ongoing commitment to keeping agencies informed and prepared, we want to share an important update related to EIDBI provisional licensure and the use of third-party consultants.

Over the past several weeks, there has been increased discussion across the provider community regarding DHS expectations for agencies that work with compliance consultants, billing agencies, and other third-party support partners. FC Consulting has proactively engaged with DHS representatives to seek clarification and ensure our guidance remains accurate and aligned with current law.

What Agencies Need to Know

• DHS has not prohibited agencies from working with compliance consultants, placement partners, or advisory firms.
• Current law requires agencies to maintain documentation related to billing agencies or other consultants and to provide that documentation to DHS upon request as part of provisional licensure or compliance reviews.
• There is no current requirement for agencies to proactively submit, list, or register third-party consultants with DHS.
• DHS has indicated that additional guidance is expected in 2026 as provisional licensure implementation continues.
• Discussions regarding potential future requirements to list third-party consultants are pending and not yet law.

FC Consulting's Role

For clarity, FC Consulting is considered an "other consultant" under current statute. This classification is neutral and expected for compliance, advisory, and placement partners.

Our role remains unchanged: - Compliance consulting and advisory support - Workforce and clinician placement assistance - No EIDBI service delivery - No Medicaid billing - No clinical supervision

All employment, supervision, and billing authority remains solely with the agency.

Our Ongoing Commitment

FC Consulting continues to update internal guidance, contract language, and client-facing materials to remain fully aligned with DHS expectations and upcoming licensure standards. We remain focused on helping agencies operate compliantly, transparently, and confidently as regulatory changes evolve.

Questions or Need Clarification?

If you have questions about how this update applies to your agency, or if you would like additional clarification, please reach out to your designated FC Consulting Compliance contact. They are available to provide guidance specific to your agency's structure and services.

Thank you for your continued partnership.