Adult day and community-based programs sit at an intersection most other licensed settings don't have to navigate: real licensing requirements from one agency, real provider-qualification requirements from another, and — for many programs — waiver-specific staffing rules layered on top of both. If your organization runs an adult day program, three things are worth a fresh look right now.
The regulation you're citing might have the wrong number on it
South Carolina's adult day care licensing framework moved from Regulation 61-75 to Regulation 60-75 as part of the broader DHEC-to-DPH restructuring — Chapter 61 became Chapter 60 across the board. The actual requirements haven't substantively changed; the number has. That sounds trivial, but it isn't: internal policies, staff training materials, and even signage that still cite "61-75" are technically referencing a superseded regulation number, and during a survey, small inconsistencies like this are exactly the kind of thing that invites closer scrutiny of everything else in the file.
What to do: a five-minute audit. Search your policy manual, orientation materials, and any posted compliance documentation for "61-75" and update every instance to "60-75." It's not a substantive fix, but it's a fast one, and it removes an easy, avoidable flag.
Licensing and waiver enrollment are two separate things — and both have to be current
This is the gap that causes real problems more often than any single missed staffing ratio. A facility providing Adult Day Health Care (ADHC) under the Community Choices Medicaid waiver needs two things current at all times, from two different agencies:
| What you need | Issued by |
|---|---|
| An active adult day care license (Regulation 60-75) | SC DPH |
| Separate, active provider qualifications to bill waiver services | SCDHHS |
Neither one substitutes for the other. It's entirely possible — and it happens — for a program to have a fully current DPH license while its SCDHHS provider agreement has lapsed or needs renewal, or vice versa. Because these are tracked by different agencies on different renewal cycles, a lapse in one can go unnoticed until it becomes a billing or licensing problem, not a routine one.
What to do: track these as two separate line items on your compliance calendar, not one combined "adult day program status" entry. Assign each to whoever owns that specific relationship, and review both independently at least quarterly.
Staffing: what R.60-75 actually requires
The regulation sets these staffing and operating requirements:
| Requirement | Section |
|---|---|
| At least one direct care staff member or volunteer for every eight participants, with records showing the ratio is met | §503.A |
| At least one staff member with first-aid and CPR certification whenever participants are present (a licensed nurse satisfies this) | §505.F |
| Prescription medication administered by a licensed nurse or an authorized healthcare provider | §1200.C |
| Operating hours of between four and fourteen hours per day | §101.J |
| A nurse on site | Not required by the regulation |
Waiver-specific nursing and case management expectations, if any, come from the SCDHHS provider manual and waiver, not the licensing regulation, so check your Community Choices provider manual directly.
What to do: check your nursing and medication-administration coverage against §505.F and §1200.C, and separately confirm any waiver-specific staffing terms in your SCDHHS provider agreement and manual.
The through-line
None of these three issues are about a single missing policy or an obviously wrong practice — they're about the seams between systems: an old regulation number in outdated materials, two separate agency relationships that need independent tracking, and staffing rules spread across several sections (ratio, first aid and CPR, medication administration) instead of stated in one place. Programs that build a habit of checking the seams, not just the individual requirements, tend to have a much smoother experience when a real review comes.
Working through this in your own organization?
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