Oregon - Day Habilitation Services — Licensing, Medicaid Enrollment and Startup Requirements

Last reviewed: 2026-09-10

The Oregon Department of Human Services (ODHS) Office of Developmental Disabilities Services (ODDS) funds Day Support Activities—the state's specific term for day habilitation—through the state's 1915(c) Comprehensive and Support Services waivers. Providers do not obtain a traditional facility license for this service; instead, they must apply for Medicaid Agency Certification under Oregon Administrative Rule (OAR) 411-323 and request a specific service endorsement for Day Support Activities.

Before an application for certification is even accepted, prospective agency directors must pass a mandatory Medicaid Agency Orientation (MAO) through an approved vendor and submit a formal market study demonstrating an unmet need for the service in their target area. Once certified by ODDS, the agency must separately enroll through the Oregon Health Authority (OHA) MMIS Provider Portal and execute an ODDS Provider Enrollment Agreement before they can bill for services.

1. Service Definition and Scope

In Oregon, day habilitation is formally categorized as Day Support Activities (DSA). This service provides structured, non-residential daytime programming designed to help adults with intellectual and developmental disabilities (I/DD) acquire, retain, or improve self-help, socialization, and adaptive skills.

DSA must be delivered in settings that fully comply with the federal HCBS Settings Rule, meaning the programming must facilitate integration and full access to the greater community, rather than isolating individuals.

• Service Nomenclature: Day Support Activities (DSA).
• Target Population: Adults with intellectual and developmental disabilities enrolled in ODDS waivers.
• Funding Authority: Oregon's 1915(c) Comprehensive Waiver and Support Services Waiver.
• Setting Requirements: Must be community-based and strictly adhere to HCBS Settings Rule integration mandates.

2. Regulatory and Oversight Agencies

The primary regulatory body for I/DD services in Oregon is the Office of Developmental Disabilities Services (ODDS), a division of the Oregon Department of Human Services (ODHS). ODDS handles the certification, service endorsements, and ongoing compliance monitoring.

The Oregon Health Authority (OHA) serves as the state Medicaid agency, managing the MMIS system and processing the actual Medicaid provider enrollment and revalidation.

• Primary Agency: Oregon Department of Human Services (ODHS) [https://www.oregon.gov/odhs]
• Operating Division: Office of Developmental Disabilities Services (ODDS) [https://www.oregon.gov/odhs/agency/pages/odds.aspx]
• Medicaid Agency: Oregon Health Authority (OHA) [https://www.oregon.gov/oha]
• Enrollment Portal: OHA MMIS Provider Portal [https://www.oregon.gov/oha/hsd/ohp/pages/provider-enroll.aspx]

3. Gatekeeping Prerequisites: Who Can Even Apply

Oregon imposes strict prerequisites before a prospective provider can submit a Medicaid Agency Certification application. The state requires a formal market study, and ODDS explicitly prioritizes applications that address unmet needs or offer services in underserved areas.

Additionally, the agency's executive director must complete a mandatory orientation program. Without the orientation certificate and a satisfactory market study, the application will not be processed.

• Market Study Requirement: Applicants must submit a market study demonstrating the need for Day Support Activities in the proposed geographic area (per OAR 411-325-0025).
• Mandatory Orientation: Executive directors must register for and pass the Medicaid Agency Orientation (MAO) via an ODDS-approved vendor prior to application.
• Financial Stability: Applicants must provide documentation proving financial stability and sufficient operating reserves.
• Network Status: Open enrollment, but heavily gated by the market study's proof of unmet need.

4. Licensure and Certification Requirements

Oregon does not issue a distinct "Day Habilitation License." Instead, organizations apply for Medicaid Agency Certification and simultaneously request a service endorsement for Day Support Activities.

The certification standards are governed by OAR 411-323. Providers must submit a comprehensive application packet, including policy manuals, organizational charts, and proof of fee payment through the state's payment portal.

• Certification Type: Medicaid Agency Certification.
• Service Endorsement: Day Support Activities Endorsement.
• Rule Citation: OAR 411-323 (Medicaid Agency Certification rules).
• Application Fee: Must be paid via the ODHS Medicaid Agency Payment Portal prior to application review.

5. Medicaid Provider Enrollment

After obtaining ODDS certification and the DSA endorsement, the agency must enroll as a Medicaid provider through the OHA MMIS Provider Portal. This step links the agency's National Provider Identifier (NPI) to the state's payment system.

Providers must also sign the ODDS Provider Enrollment Agreement. Services cannot be provided or billed until this agreement is fully executed by the ODDS Contract Unit.

• Enrollment System: OHA MMIS Provider Portal.
• Required Agreement: ODDS Provider Enrollment Agreement (PEA).
• NPI Requirement: Agencies must obtain and submit a Type 2 (Organizational) NPI.
• Disclosure Form: Must complete the standard Medicaid Provider Disclosure Form detailing ownership and control interests.

6. Staffing, Training and Background Checks

All personnel, including executive directors and Direct Support Professionals (DSPs), must clear rigorous background checks before having contact with individuals. Oregon processes these through the Background Check Unit (BCU) using the ORCHARDS system.

Agencies must ensure staff complete ODDS-mandated training, including modules on behavioral support plans, incident reporting, and the HCBS Settings Rule.

• Background Checks: Processed via the ODHS Background Check Unit (BCU) through the ORCHARDS system.
• Director Qualifications: Executive Directors must meet specific education and experience thresholds outlined in OAR 411-323.
• Mandatory Training: Staff must be trained on individual behavioral support plans, safety protocols, and HCBS Settings compliance.
• CPR/First Aid: All direct-care staff must maintain current, hands-on CPR and First Aid certification.

7. Documentation, Policies and Records

Certified agencies must maintain an extensive policy and procedure manual that aligns with OAR 411-323. This includes detailed protocols for incident management, grievance procedures, and quality assurance.

At the participant level, providers must maintain records that track progress against the goals outlined in each person's Individual Support Plan (ISP), as developed by their local Community Developmental Disabilities Program (CDDP) or brokerage.

• Individual Support Plan (ISP): Services must be delivered and documented in strict accordance with the authorized ISP.
• Incident Reporting: Policies must dictate immediate reporting of abuse, neglect, or critical incidents to ODDS.
• Financial Records: Agencies must maintain auditable financial records demonstrating ongoing stability.
• HCBS Compliance Documentation: Records must prove the setting facilitates community integration and individual choice.

8. Billing, Rates and Claims

Billing for Day Support Activities is managed through the eXpress Payment & Reporting System (eXPRS). Providers submit claims based on the authorizations entered into eXPRS by the local CDDP or brokerage.

Rates are established by ODDS and are typically based on the specific service code, staffing ratios, and the duration of the service provided.

• Billing System: eXpress Payment & Reporting System (eXPRS).
• Authorization: Claims will only pay if a valid authorization exists in eXPRS from the CDDP/brokerage.
• Rate Structure: Standardized fee-for-service rates published in the ODDS expenditure guidelines.
• Payment Method: Processed via Electronic Funds Transfer (EFT) through the OHA MMIS.

9. Approval Sequence and Timeline

The approval process is sequential and cannot be rushed. It begins with the mandatory orientation and market study, followed by the formal certification application to ODDS.

Once certified, the OHA MMIS enrollment and ODDS contracting phases add several more weeks. The entire process typically takes 4 to 6 months from the initial orientation to the first billable date.

• Step 1: Complete the Medicaid Agency Orientation (MAO) and prepare the market study.
• Step 2: Submit the Medicaid Agency Certification application and fee to ODDS.
• Step 3: Upon certification, submit the enrollment application via the OHA MMIS Provider Portal.
• Step 4: Execute the ODDS Provider Enrollment Agreement and obtain eXPRS system access.

10. Common Denials and Survey Findings

Applications are frequently delayed or denied at the very first step if the market study fails to convincingly demonstrate an unmet need for Day Support Activities in the target county.

During initial reviews and subsequent surveys, ODDS commonly cites providers for incomplete policy manuals, failure to properly document staff training, or allowing staff to work before their ORCHARDS background check is fully cleared.

• Market Study Rejection: Application denied due to insufficient evidence of unmet need.
• Background Check Violations: Staff providing services prior to official BCU/ORCHARDS clearance.
• Policy Deficiencies: Missing required elements in the agency's grievance or incident reporting policies.
• HCBS Non-Compliance: Proposed day program settings that isolate individuals from the broader community.

11. Key Contacts and Resources

Prospective providers should rely on the official ODHS and OHA portals for the most current forms, rule citations, and fee schedules.

The ODDS Prospective Providers page is the central hub for the Medicaid Agency Certification process, while the OHA site handles the MMIS enrollment mechanics.

• ODDS Prospective Providers Page: [https://www.oregon.gov/odhs/licensing/idd-agencies/Pages/prospective-providers.aspx]
• OHA Provider Enrollment: [https://www.oregon.gov/oha/hsd/ohp/pages/provider-enroll.aspx]
• eXPRS System Login: [https://apps.state.or.us/exprsWeb/]
• OAR 411-323 Rule Text: [https://secure.sos.state.or.us/oard/displayDivisionRules.action?selectedDivision=1805]

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