Building a Winning CDS Program: What Every Missouri Provider Needs to Know

Starting or improving a Consumer Directed Services (CDS) program in Missouri is one of the best ways to empower individuals with disabilities and seniors to live independently — but it’s also a responsibility that requires strong compliance, structure, and oversight. Whether you’re a new provider or already operating, building a winning CDS program means understanding the regulations, training your staff effectively, and maintaining consistent communication with participants and the Department of Health and Senior Services (DHSS).

1. Understand the Foundation of the CDS Program

The CDS program allows eligible Missourians to hire and direct their own personal care attendants, with the support of an approved provider agency. As a provider, your role is to manage payroll, ensure compliance, train attendants, and oversee documentation. To stay compliant, agencies must follow 13 CSR 70-91.010, which outlines requirements for training, participant rights, RN oversight, and service documentation. Building your program around these rules helps prevent costly mistakes during audits or reviews.

2. Train and Support Personal Care Attendants

Training is at the heart of a successful CDS program. Missouri requires that attendants receive a minimum of 12 hours of initial training covering personal care tasks, safety, infection control, emergency procedures, and participants’ rights. Advanced Personal Care (APC) attendants must also complete an additional 6-hour RN-supervised training to perform higher-level tasks safely. Beyond compliance, ongoing coaching and check-ins create stronger, more confident attendants who provide higher-quality care.

3. Strengthen Participant Communication

Participants are the center of the CDS model, and maintaining open, respectful communication is key. Providers should ensure that participants:

• Clearly understand their responsibilities as employers

• Know how to report schedule changes, incidents, or concerns

• Receive guidance in completing required forms and timesheets

Strong participant engagement reduces confusion, improves service satisfaction, and protects the agency from compliance risks.

4. Maintain RN Oversight and Quality Assurance

Registered Nurse (RN) oversight isn’t just a formality it’s essential for participant safety and program integrity. The RN ensures that care plans are appropriate, observes task competencies, and monitors attendants’ performance. Establishing a regular RN visit schedule and documenting all training and supervision activities is critical for compliance with DHSS and MO HealthNet standards.

5. Keep Your Documentation Audit-Ready

Every CDS provider must maintain organized, up-to-date records for participants, attendants, and service delivery. This includes:

• EVV logs

• RN visit notes and training documentation

• Participant eligibility and care plan forms

A structured documentation system ensures you’re always ready for audits and reviews and helps your agency run more efficiently day to day.

6. Stay Current with State Policy Changes

Missouri’s CDS regulations can evolve, especially regarding EVV, training requirements, or reimbursement procedures. Successful providers make it a habit to review updates from MO HealthNet Division and DHSS regularly to stay ahead of changes.

A winning CDS program is built on compliance, communication, and care. When your agency invests in proper training, clear oversight, and strong participant relationships, you don’t just meet state requirements you build a trusted, high-quality service that makes a real difference in people’s lives.