Pennsylvania - Adult Companion Services — Licensing, Medicaid Enrollment and Startup Requirements

Last reviewed: 2026-09-10

The Pennsylvania Department of Human Services (DHS), through the Office of Developmental Programs (ODP), funds Companion Services under the Consolidated, Community Living, and Person/Family Directed Support (P/FDS) waivers.

Before an agency can bill the PROMISe Medicaid system for this unlicensed service, it must secure provider qualification approval from a designated county Administrative Entity (AE) using form DP 1059 and complete the mandatory ODP New Provider Applicant orientation.

1. Service Definition and Scope

In Pennsylvania, Companion Services provide non-medical supervision and socialization to ensure the health and safety of adults (aged 18 and older) with intellectual disabilities or autism.

This service is delivered in private homes or community settings and is distinct from residential habilitation or supported employment, focusing instead on maintaining the participant's safe integration in the community.

• Target Population: Adults aged 18 and older enrolled in ODP waivers.
• Core Activities: Supervision, socialization, and minimal assistance with daily living tasks incidental to the companion role.
• Excluded Activities: Medical care, routine housekeeping not related to the participant, and tasks covered by residential habilitation.
• Setting Requirements: Must be provided in the participant's private home or integrated community settings, compliant with the CMS HCBS Final Rule.

2. Regulatory and Oversight Agencies

The Pennsylvania Department of Human Services (DHS) is the single state Medicaid agency responsible for overall program administration.

The Office of Developmental Programs (ODP) directly manages the waivers funding Companion Services, while county-level Administrative Entities (AEs) handle local provider qualification and oversight.

• Pennsylvania Department of Human Services (DHS): Oversees all Medicaid operations (https://www.dhs.pa.gov).
• Office of Developmental Programs (ODP): Administers the Consolidated, Community Living, and P/FDS waivers (https://www.dhs.pa.gov/about/DHS-Information/Pages/Office-of-Developmental-Programs.aspx).
• Administrative Entities (AEs): County or multi-county mental health/intellectual disability offices that approve provider qualifications (https://www.myodp.org/course/view.php?id=875).
• PROMISe: The Pennsylvania Medicaid Management Information System used for enrollment and claims (https://promise.dpw.state.pa.us).

3. Gatekeeping Prerequisites: Who Can Even Apply

Pennsylvania does not require a Certificate of Need, competitive RFP procurement, or closed-network managed care contracting to provide ODP Companion Services.

The mandatory structural precondition is the ODP New Provider Applicant process, which requires an applicant to complete state-mandated orientation and secure formal qualification approval from a designated county Administrative Entity (AE) before DHS will accept a Medicaid enrollment application.

• Certificate of Need: None exists for this service in Pennsylvania.
• Procurement/RFP: None; enrollment is open to any willing provider that meets ODP qualifications.
• New Provider Orientation: Applicants must complete the ODP New Provider Applicant orientation before submitting qualification documents.
• AE Sponsorship/Approval: Applicants must submit the DP 1059 Provider Qualification form to their assigned AE and receive approval before applying to PROMISe.

4. Licensure and Certification Requirements

Companion Services are an unlicensed HCBS service in Pennsylvania. The state does not issue a facility or agency license for this specific service.

Instead of licensure, providers achieve certification to operate by meeting the regulatory standards outlined in 55 Pa. Code Chapter 6100 and maintaining approved status on the ODP Provider Qualification Documentation Record.

• Licensure Status: Unlicensed service; no facility license is issued by DHS for Companion Services.
• Regulatory Framework: Providers must comply with 55 Pa. Code Chapter 6100 (Support for Individuals with Intellectual Disabilities or Autism).
• Self-Assessment: New providers must complete the ODP New Provider Self-Assessment and Guidelines document.
• Revalidation: Provider qualification must be revalidated by the AE every three years.

5. Medicaid Provider Enrollment

Once qualified by the AE, providers must enroll in the Pennsylvania Medical Assistance program through the DHS electronic provider enrollment portal.

Following PROMISe enrollment, providers must register in the Home and Community Services Information System (HCSIS) to receive service authorizations and view Individual Support Plans (ISPs).

• Enrollment Portal: Applications are submitted via the DHS electronic provider enrollment portal (https://provider.enrollment.dpw.state.pa.us).
• Provider Type/Specialty: Providers enroll under specific ODP provider types and specialties designated for Companion Services.
• Application Fee: Subject to the federal Medicaid institutional provider application fee unless waived or paid to Medicare/another state.
• HCSIS Registration: Mandatory system registration for ODP waiver providers to manage authorizations (https://www.hcsis.state.pa.us).

6. Staffing, Training and Background Checks

Direct support professionals delivering Companion Services must meet the minimum qualifications established in the approved ODP waiver appendices and Chapter 6100 regulations.

Agencies must secure all required criminal history and child abuse clearances before a staff member has direct contact with a participant.

• Age Requirement: Staff must be at least 18 years of age.
• Criminal History: Pennsylvania State Police criminal history clearance is required for all staff.
• FBI Clearance: Required if the employee has not been a continuous resident of Pennsylvania for the past two years.
• Child Abuse Clearance: Required under the Child Protective Services Law if serving participants under age 21.
• Training: Staff must be trained on the specific needs detailed in the participant's Individual Support Plan (ISP) prior to service delivery.

7. Documentation, Policies and Records

Providers must maintain strict service documentation as outlined in ODP Bulletin 00-17-02 to justify Medicaid claiming.

Agencies are also required to implement comprehensive policies covering incident management, quality management, and HCBS Final Rule compliance.

• Service Notes: Must include date, name of recipient, provider name, nature/extent of service, and place of service.
• ISP Alignment: Documentation must demonstrate that services were rendered exactly as authorized in the person-centered ISP.
• Incident Management: Providers must utilize the Enterprise Incident Management (EIM) system to report critical incidents.
• Record Retention: Records must be retained for a minimum of five years or until all audit questions are resolved.

8. Billing, Rates and Claims

Claims for Companion Services are submitted to the PROMISe system and are paid according to a standardized fee schedule established by ODP.

Providers must verify participant eligibility through the Eligibility Verification System (EVS) prior to billing.

• Billing System: Claims are processed through PROMISe.
• Fee Schedule: Rates are published annually in the Pennsylvania Bulletin and on MyODP.
• Unit of Service: Typically billed in 15-minute increments as defined by the ODP procedure code chart.
• Electronic Visit Verification (EVV): Companion services provided in the home may be subject to DHS EVV requirements depending on the exact service location and delivery model.

9. Approval Sequence and Timeline

The approval process is sequential, beginning with ODP training and local AE review before advancing to state-level Medicaid enrollment.

The entire process typically takes several months, heavily dependent on the provider's readiness and the AE's review schedule.

• Step 1: Complete ODP New Provider Applicant orientation.
• Step 2: Submit DP 1059 and supporting policies to the assigned AE for qualification review.
• Step 3: Receive AE approval and submit the Medicaid enrollment application via the DHS portal.
• Step 4: Receive PROMISe ID and register in HCSIS to begin receiving authorizations.

10. Common Denials and Survey Findings

Initial qualification applications are frequently returned by AEs if the provider's policies do not explicitly align with Chapter 6100 regulations or the HCBS Final Rule.

During post-enrollment Quality Assessment and Improvement (QA&I) reviews, providers often face citations for inadequate service documentation.

• Policy Deficiencies: Generic policies that fail to reference Pennsylvania-specific ODP regulations.
• Missing Clearances: Failure to obtain or document required background checks prior to staff hire dates.
• Unsubstantiated Claims: Billing PROMISe without corresponding service notes that meet ODP Bulletin 00-17-02 standards.
• Incident Reporting: Failure to report critical incidents in the EIM system within the mandated timeframes.

11. Key Contacts and Resources

The primary hub for ODP provider training, qualification forms, and policy bulletins is the MyODP portal.

Technical assistance for Medicaid enrollment is handled by the DHS Provider Enrollment unit.

• MyODP Portal: Central resource for ODP training and communications (https://www.myodp.org).
• DHS Provider Enrollment: Manages PROMISe applications (https://provider.enrollment.dpw.state.pa.us).
• PROMISe Help Desk: Technical support for claims and portal access (https://promise.dpw.state.pa.us).
• ODP Regional Offices: Provide oversight and support to AEs and providers across the state (https://www.dhs.pa.gov/about/DHS-Information/Pages/Office-of-Developmental-Programs.aspx).

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