3.25 Appendix 1 Consumer Directed Services Tax Information
Home and Community Based Services Manual
3.25 Appendix 1 Consumer Directed Services Tax Information
Revised - April 2026
Introduction
Consumer Directed Services (CDS) providers are responsible for fiscal and consumer support functions that enable individuals to self-direct personal care services. This includes handling the participant's financial tasks, such as ensuring all payroll, employment, and other taxes are filed and paid on time using the consumer's tax ID number.
Purpose
The purpose of this policy is to ensure that CDS providers accurately manage employer-related tax responsibilities, maintain compliance with federal and state requirements, and properly document all required tax information in the HCBS electronic case record to protect participants from financial risk and ensure timely, transparent support.
Provider Requirements
CDS Provider must:
- Ensure the Employer/Payer Appointment of Agent Form (IRS 2678) is accurately completed and submitted, allowing the provider to manage federal employment tax responsibilities on behalf of the participant. The form should be completed at initiation of CDS or whenever the participant changes CDS providers.
- Complete all required tax activities on time and is responsible for any garnishment actions that occur because the provider failed to pay payroll, employment, or other taxes on the consumer’s behalf.
- Notify the consumer of any communication from federal, state, or local tax authorities regarding overdue or unpaid taxes, including any notice of a potential garnishment.
- Complete required documentation in the HCBS electronic case record (Fusion). This includes:
- Entering the tax ID information on the main participant's page under the ‘HCBS Eligibility section
- Uploading proof of the information under the ‘documents’ tab. The documents shall be uploaded using the ‘EIN Tax Documents’ category in the dropdown selection. Documents shall be uploaded to the electronic case record within ninety (90) days of the CDS start date. If another CDS provider has already added the documents to the record, they do not need to be uploaded again.
The CDS Provider shall facilitate the completion of the Employer/Payer Appointment of Agent (IRS 2678) and ensure its completion by both parties.
Acceptable Documents for Verification
Acceptable documents for the assignment of a Federal EIN:
- CP 575 or 147C Letter
- 940 Employer’s Annual Federal Unemployment (FUTA) Tax Return
- 941 Employers Quarterly Federal Tax Return
- A letter from the IRS with the Tax ID number and legal name
- Any IRS document that has the legal name and TAX number preprinted
NOTE: W-9 forms or digital copies not on official letterhead are not acceptable for verification.
Acceptable documents for the assignment of a Missouri EIN/TIN:
- A copy of the notice from the MO Department of Revenue
- MO 941 Employer’s Return of Income Taxes Withheld
- MO W-3 Transmittal of Tax Statements
NOTE: If a document includes both the FEIN and MO EIN/TIN, no further documentation of either is required.