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

Last reviewed: 2026-08-16

In Pennsylvania, Adult Companion Services are non-medical supervision and socialization supports designed to ensure the health, safety, and community integration of adults with disabilities. These services are primarily funded through Home and Community-Based Services (HCBS) waivers administered by the Department of Human Services (DHS), specifically the Office of Developmental Programs (ODP) for individuals with intellectual disabilities and autism, and the Office of Long-Term Living (OLTL) for aging adults and those with physical disabilities.

The single biggest structural barrier to entry for prospective providers in Pennsylvania is the bifurcated gatekeeping system: to serve the aging/physical disability population under the Community HealthChoices (CHC) waiver, providers face a closed-network barrier and must secure a contract with one of the state's designated Managed Care Organizations (MCOs). Conversely, to serve the intellectual disability/autism population, providers must pass a rigorous, multi-step Provider Qualification process through the Home and Community Services Information System (HCSIS) before the state will even accept a Medicaid enrollment application.

1. Service Definition and Scope

Companion Services in Pennsylvania provide non-medical care, supervision, and socialization to adults (age 18 and older) to help them remain safely in their communities. The service focuses on ensuring health and safety while facilitating community participation, but it strictly excludes hands-on personal care, which falls under In-Home and Community Support or Personal Assistance Services.

This service is covered under multiple Pennsylvania Medicaid waivers, including the Consolidated, Community Living, Person/Family Directed Support (P/FDS), and Adult Autism waivers under ODP, as well as the Community HealthChoices (CHC) waiver under OLTL. Providers must adhere to the specific service definitions outlined in the approved federal 1915(c) waiver appendices.

• Target Population: Adults aged 18 and older enrolled in specific ODP or OLTL Medicaid waivers.
• Covered Activities: Socialization, supervision for health and safety, and minimal assistance with daily living tasks that do not require hands-on care.
• Excluded Activities: Medical treatments, nursing care, and hands-on personal care such as bathing, dressing, or feeding.
• Service Settings: The participant's private home or integrated community settings within Pennsylvania.
• ODP Waiver Authorities: Consolidated Waiver, Community Living Waiver, Person/Family Directed Support (P/FDS) Waiver, and Adult Autism Waiver.
• OLTL Waiver Authority: Community HealthChoices (CHC) Waiver.

2. Regulatory and Oversight Agencies

The Pennsylvania Department of Human Services (DHS) is the umbrella agency responsible for all Medicaid HCBS programs. Within DHS, oversight is divided by target population: the Office of Developmental Programs (ODP) manages waivers for individuals with intellectual disabilities and autism, while the Office of Long-Term Living (OLTL) manages waivers for aging adults and individuals with physical disabilities.

While Companion Services do not have a standalone license category, agencies providing these services often fall under the regulatory purview of the Pennsylvania Department of Health (DOH) if they operate as a Home Care Agency. For ODP waivers, local oversight is also provided by county-level Administrative Entities (AEs).

• Umbrella Agency: Pennsylvania Department of Human Services (DHS) administers the state Medicaid program.
• ID/A Waiver Oversight: Office of Developmental Programs (ODP) oversees the Consolidated, Community Living, P/FDS, and Adult Autism waivers.
• Aging/Physical Disability Oversight: Office of Long-Term Living (OLTL) oversees the Community HealthChoices (CHC) waiver.
• Licensing Authority: Pennsylvania Department of Health (DOH) licenses Home Care Agencies.
• Local Oversight: County Administrative Entities (AEs) manage local provider qualification and capacity for ODP waivers.

3. Gatekeeping Prerequisites: Who Can Even Apply

Pennsylvania enforces strict structural preconditions that block applicants before a Medicaid enrollment application is accepted. For OLTL's Community HealthChoices (CHC) waiver, the state utilizes a managed care model; providers cannot enroll as standalone fee-for-service entities for CHC and must secure a contract with a designated MCO, which often enforce closed networks based on regional need.

For ODP waivers, providers face a mandatory pre-enrollment qualification gate. An applicant cannot submit a PROMISe Medicaid enrollment application until they have completed the mandatory ODP Applicant Orientation, registered in the Home and Community Services Information System (HCSIS), and received formal Provider Qualification approval from their designated Administrative Entity (AE) or ODP.

• OLTL/CHC Barrier: Mandatory contracting with at least one CHC Managed Care Organization (UPMC, PA Health & Wellness, or AmeriHealth Caritas), subject to MCO network adequacy closures.
• ODP Barrier 1: Mandatory completion of the ODP Provider Applicant Orientation before HCSIS registration is permitted.
• ODP Barrier 2: Formal Provider Qualification approval via the Home and Community Services Information System (HCSIS) is required before PROMISe enrollment.
• Business Registration: Must be registered with the Pennsylvania Department of State and possess a valid Employer Identification Number (EIN).
• NPI Requirement: Must obtain a National Provider Identifier (NPI) prior to initiating the Medicaid enrollment process.
• System Access: Must register for a Business Partner Network (BPN) account to access HCSIS for the qualification process.

4. Licensure and Certification Requirements

Pennsylvania does not issue a distinct "Companion Services License." If an agency provides companion services alongside personal care or other home care services, they must obtain a Home Care Agency license from the Pennsylvania Department of Health (DOH) under 28 Pa. Code Chapter 611.

If a provider exclusively offers non-medical companion services under ODP waivers and does not meet the statutory definition of a Home Care Agency, they may operate unlicensed but must meet the rigorous certification and qualification standards outlined in Appendix C of the respective ODP waivers. This requires submitting comprehensive policy manuals for state review.

• Applicable License: Pennsylvania DOH Home Care Agency License (required if the agency's scope meets the Chapter 611 definition).
• Regulation Citation: 28 Pa. Code Chapter 611 (Home Care Agencies and Home Care Registries).
• ODP Qualification Standard: Must meet waiver-specific provider qualifications outlined in Appendix C of the approved 1915(c) waivers.
• Application Portal: DOH Message Center/Enterprise Licensing System for Home Care Agency applications.
• Insurance Requirements: Must maintain Commercial General Liability, Worker's Compensation, and Professional Liability insurance.
• Policy Validation: ODP validates that written policies genuinely meet its standards before granting qualification.

5. Medicaid Provider Enrollment

Once a provider has passed the ODP qualification gate or secured DOH licensure and MCO contracts, they must enroll in PROMISe, Pennsylvania's Medicaid Management Information System. Enrollment is processed through the DHS Electronic Provider Enrollment (ePE) portal.

Providers must enroll under specific Provider Types and Specialties depending on their structure and the waivers they intend to bill. Out-of-state providers are generally not permitted to enroll for HCBS unless they maintain a physical service location within Pennsylvania or a bordering county.

• Medicaid System: PROMISe (Provider Reimbursement and Operations Management Information System).
• Enrollment Portal: DHS Electronic Provider Enrollment (ePE) application.
• Provider Type: Typically enrolls as Provider Type 59 (Atypical) or Provider Type 38 (Home Care Agency), depending on licensure status.
• Application Fee: Subject to the ACA institutional provider application fee (approximately $732) unless waived or already paid to Medicare.
• Service Location: Must enroll each physical service location separately in PROMISe.
• Revalidation: Federal regulations require state Medicaid agencies to revalidate provider enrollment at least every 5 years.

6. Staffing, Training and Background Checks

Pennsylvania requires strict background clearances for all direct support professionals (DSPs) and companions before they can provide services. Reputable, licensed agencies are legally required to complete thorough background checks, including state police and child abuse clearances.

Training requirements are dictated by the overseeing agency. ODP requires extensive initial and annual training for all staff providing waiver services, while DOH Chapter 611 outlines specific competency and training requirements for Home Care Agency staff.

• Minimum Age: Companions must be at least 18 years of age.
• Criminal Background Check: Pennsylvania State Police (PATCH) criminal record check required prior to hire.
• Child Abuse Clearance: Pennsylvania Child Abuse History Clearance required if serving individuals under 18 or per agency policy.
• FBI Clearance: FBI fingerprint-based background check required if the applicant has lived outside Pennsylvania in the past 2 years.
• ODP Initial Training: Requires 24 hours of training within the first year, covering incident management, participant rights, and individual support plans.
• ODP Annual Training: 24 hours of annual training required for all direct support staff under ODP waivers.
• First Aid/CPR: Staff must maintain current certification in First Aid and CPR.

7. Documentation, Policies and Records

Providers must develop and maintain comprehensive operational policies that align with Pennsylvania regulations. During the ODP qualification process, agencies must upload a compliant operational manual; submitting generic policies or manuals containing a different agency's name will result in immediate rejection.

Additionally, providers must comply with federal Electronic Visit Verification (EVV) mandates for companion services. Pennsylvania utilizes Sandata as its state-sponsored EVV system, though providers may use an alternate approved EVV system that integrates with the state aggregator.

• Quality Management Plan: Must maintain a written QM plan meeting ODP or OLTL standards.
• Incident Management Policy: Must align with the Pennsylvania Enterprise Incident Management (EIM) system reporting requirements.
• Record Retention: Medicaid records, including service notes and billing data, must be retained for a minimum of 5 years.
• EVV Compliance: Electronic Visit Verification (EVV) is mandatory for companion services under the 21st Century Cures Act.
• Service Notes: Documentation must include date, start/stop times, specific activities provided, and the participant's response.
• Policy Customization: Full operational manuals must be customized to Pennsylvania rules; generic templates are not accepted.

8. Billing, Rates and Claims

Billing procedures depend on the waiver authority. For ODP waivers, providers bill fee-for-service directly through the PROMISe system using rates established annually by DHS and published in the Pennsylvania Bulletin. For the CHC waiver, providers submit claims directly to the contracted MCO's clearinghouse.

All claims for Companion Services must be supported by corresponding EVV data. If the EVV system does not show a verified visit matching the billed units, the claim will be denied by PROMISe or the MCO.

• Billing System (ODP): Claims are submitted directly to the PROMISe system.
• Billing System (CHC): Claims are submitted to the respective MCO's claims clearinghouse.
• Procedure Code: Typically billed using HCPCS code W1726 (Companion Services) or a similar waiver-specific code.
• Unit of Service: Services are generally billed in 15-minute increments.
• Rate Setting: ODP fee schedule rates are established by DHS and published annually in the Pennsylvania Bulletin.
• EVV Linkage: Claims will automatically deny if not matched with corresponding check-in/check-out data in the EVV aggregator.

9. Approval Sequence and Timeline

Becoming a Companion Services provider in Pennsylvania is a strictly sequential process. An applicant cannot enroll in PROMISe until they have cleared the programmatic gatekeepers (ODP qualification or DOH licensure/MCO contracting).

The entire process from initial orientation to billing readiness typically takes 6 to 9 months, depending on the speed of state reviews, the accuracy of submitted policy manuals, and MCO contracting timelines.

• Step 1: Register for and complete the ODP Applicant Orientation (scheduling can take 1-2 months).
• Step 2: Submit Provider Qualification application via HCSIS (AE/ODP review typically takes 30-60 days).
• Step 3: Apply for DOH Home Care Agency License, if applicable (DOH review takes 60-90 days).
• Step 4: Submit PROMISe Enrollment via the ePE portal (processing takes 30-45 days).
• Step 5: For CHC, apply for MCO network contracting (takes 90-120+ days, subject to network need).

10. Common Denials and Survey Findings

Applications are frequently delayed or denied due to administrative errors or failure to meet Pennsylvania-specific standards. ODP validates that written policies genuinely meet its standards, so submitting generic, out-of-state policy templates is a primary cause for rejection.

During post-enrollment surveys or audits, providers often face citations for failing to maintain continuous background clearances, inadequate service note documentation, or failing to report incidents through the EIM system within the mandated timeframes.

• Policy Deficiencies: Submitting generic policy manuals that do not reference Pennsylvania ODP regulations or EIM procedures.
• Address Mismatches: Discrepancies between the IRS W-9, DOH license, and PROMISe application addresses.
• Missing Clearances: Failure to secure FBI clearances for staff who have lived outside Pennsylvania in the past 2 years.
• EVV Non-Compliance: Failing to properly integrate an alternate EVV system with the state's Sandata aggregator.
• MCO Network Closure: CHC applications denied because the MCO determines there is adequate provider capacity in the requested county.
• Incident Reporting: Audit findings for failing to report critical incidents in the EIM system within 24 hours.

11. Key Contacts and Resources

Prospective providers must utilize specific state portals and help desks to navigate the enrollment and qualification process. The DHS website provides access to the ePE portal, HCSIS, and waiver-specific provider manuals.

For technical assistance, providers should rely on the designated customer service centers for ODP, PROMISe enrollment, and EVV support rather than general state hotlines.

• ODP Provider Qualification: ODP Customer Service Center at RA-customerservice@pa.gov.
• Medicaid Enrollment: DHS Provider Enrollment Unit at 1-800-537-8862.
• Licensing: Pennsylvania DOH Division of Home Health at RA-DHHQA@pa.gov.
• System Access: HCSIS Help Desk for Business Partner Network (BPN) and qualification portal issues.
• EVV Support: Pennsylvania DHS EVV resource page and Sandata technical support desk.
• MCO Contracting: Provider relations departments for UPMC, PA Health & Wellness, and AmeriHealth Caritas.

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