AI agents for business finance: what they can and can't do
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The short answer
To run a Medicare-certified home health agency, you need a state licence first, then to meet the federal conditions of participation in 42 CFR Part 484 and pass a survey, and you must show CMS initial reserve operating funds covering at least the first three months after billing privileges start, at least half of it not borrowed (42 CFR 489.28). Your nursing licence lets you deliver care; it does not license the agency.
Agency licence versus nursing licence
Many Nigerian nurses in the US have the clinical skills to run a home health service. The agency, though, is a separate regulated body. CMS's home health agency page (modified 17 August 2026) says an HHA must be licensed under state or local law, or approved as meeting the state's licensing standards, and must meet federal health and safety requirements. The state licence is set by the state health or human services agency, and the categories differ: some states separate skilled home health (nursing, therapy) from personal care or companion services. In Texas, for example, home health is licensed by the Health and Human Services Commission; check its current licensing pages and any pre-application training before you file.
| Model | Typical payer | Regulation |
|---|---|---|
| Non-medical home care (personal care, companionship) | Private pay, some Medicaid programmes | State licence in many states; no Medicare certification |
| Licensed home health, private pay | Private pay, insurers | State licence |
| Medicare-certified home health | Medicare, plus others | State licence, 42 CFR 484 conditions, survey, 42 CFR 489.28 capital |
The Medicare route
- Form the business entity and get a state licence for home health.
- Build policies and staffing to the conditions of participation in 42 CFR Part 484 (patient rights, care planning, clinical records, quality programme, supervision).
- Enrol with Medicare and arrange the initial survey.
- Show capitalisation under 42 CFR 489.28 at application and through the first three months after billing privileges start.
- Begin billing once certified.
Expect this to take months, with patients needed before survey. Many agencies run on private pay first, which also helps prove the processes work.
The capital rule, explained
Under 42 CFR 489.28, a new HHA must have initial reserve operating funds available when it applies and for three months after Medicare billing privileges are conveyed. The amount is based on comparable agencies: their average first-year cost per visit multiplied by your projected visits for the first three months, with a floor tied to the comparison agencies' average visits. Key points:
- Projected Medicare receivables do not count.
- At least 50% must be non-borrowed funds, such as the owners' own investment.
- The rest can be a loan or line of credit from an unrelated lender, with a lender's letter.
- Proof is account statements plus, where offered, a bank officer's attestation that the funds are available.
- CMS may deny billing privileges if the requirement is not met, or revoke them if funds are not kept up.
Worked example
Example only: suppose the comparable agencies' average cost per visit is $150 and you project 1,200 visits in the first three months. Reserve required: $150 x 1,200 = $180,000. At least half, $90,000, must be your own non-borrowed funds; up to $90,000 can come from an unrelated lender's line of credit. Real figures come from the comparison agencies' cost reports, not from these assumptions.
Other start-up costs to plan for
- State licence fees and any required training.
- Accreditation or survey costs.
- Professional and general liability insurance, and workers' compensation where required.
- Electronic health records and billing software.
- Clinical staff salaries before revenue arrives, since Medicare and insurers pay after the visit.
We have not given dollar figures for these because they vary by state and supplier and we could not source current ones. Get quotes before you settle on the capital plan. Funding routes are in SBA microloans for immigrant entrepreneurs and getting an SBA loan.
Mistakes that delay certification
- Counting expected Medicare payments towards reserves; 42 CFR 489.28 excludes Medicare receivables, actual or projected.
- Borrowing the whole reserve. At least half must be non-borrowed, and the officer certifying the cost report attests to that.
- Letting the reserve fall after approval. CMS can revoke billing privileges if the funds are not maintained through the three-month period.
- Treating the state licence as the finish line. The federal conditions in 42 CFR Part 484 and the survey come after it, and they examine how the agency actually runs.
A change of ownership that creates a new provider number counts as a new HHA for the capital rule, so a nurse buying an existing agency should check whether the reserve test applies again.
Where Pryme fits
The capital rule rewards clean, provable balances. A Pryme Business Account gives your US business USD account details, and verifiable statements through VerifyDoc.ai can be checked as unaltered by anyone who receives them. The Finance agent can track reserve balances for a person to review. Outside Nigeria, Pryme's activities are carried out through regulated partners.
Questions people ask
Can a Nigerian nurse own a home health agency in the US?
Yes. Ownership is open to qualifying owners; the agency needs its own state licence and, for Medicare, certification and capital. Nursing licences cover the clinical staff.
How much money do I need to start a Medicare home health agency?
42 CFR 489.28 requires reserve funds based on comparable agencies' costs for your first three months of projected visits, at least half not borrowed.
Can I borrow the capital for a home health agency?
Up to half, from an unrelated lender with a lender's letter. At least 50% must be non-borrowed funds.
Is non-medical home care easier to start?
Usually, as it does not need Medicare certification, but many states still license it. Check your state's rules.
Sources
- CMS: Home health agencies, certification and compliance (modified 17 Aug 2026) · accessed Oct 2026
- eCFR: 42 CFR 489.28, special capitalization requirements for HHAs · accessed Oct 2026
This article is general information, not financial, legal or tax advice. Products described are provided under the terms on this site and are subject to regulation and eligibility.