Paying a service provider with a virtual card does not exempt that provider from the qualification and verification requirements of California's Self-Determination Program. Appendix C of the approved 1915(c) waiver (CA.1166.R01.00) sets the license, certification, and other standards required for each waiver service, and names the FMS and the participant as the parties responsible for verifying that a provider meets them — upon selection and annually thereafter through the IPP process. The method of payment (virtual card, ACH, check) has no bearing on this requirement. Before a virtual card can be issued to a service provider, FMS Pay must have a complete vendor file on record, which may include: a valid business license; the professional license or certification required for that service under Appendix C; a signed Appendix C Confirmation Form where the service carries no specific licensure or certification requirement; and a cleared criminal background check where the provider furnishes direct personal care (W&IC sections 4689.2 to 4689.6). The card cannot be issued until verification is complete. Vendor qualification requirements: https://myfmspay.zohodesk.com/portal/en/kb/articles/vendor-qualifications