Pennsylvania - Case Management Service — Licensing, Medicaid Enrollment and Startup Requirements
Last reviewed: 2026-09-10
The Pennsylvania Department of Human Services (DHS) funds case management through its Medicaid waivers under the title Supports Coordination, requiring prospective agencies to pass the Office of Developmental Programs (ODP) or Office of Long-Term Living (OLTL) Provider Qualification process before applying for Medicaid enrollment. Pennsylvania does not issue a traditional facility or agency license for this service; instead, operating authority is granted through waiver-specific qualification and subsequent enrollment in the Provider Reimbursement and Operations Management Information System (PROMISe).
For providers targeting the aging and physical disability populations under OLTL, the structural precondition is securing network contracts with the Community HealthChoices (CHC) Managed Care Organizations (MCOs), which frequently close their networks based on regional adequacy. For intellectual and developmental disability populations under ODP, providers must secure an operating agreement with a county Administrative Entity (AE) after completing the state's mandatory New Provider Orientation and qualification packet.
1. Service Definition and Scope
In Pennsylvania, Medicaid HCBS case management is officially designated as Supports Coordination or Targeted Support Management (TSM). This service involves locating, coordinating, and monitoring services and supports for waiver participants to ensure their health, safety, and welfare.
Supports Coordinators (SCs) are responsible for conducting needs assessments, developing the Individual Support Plan (ISP) or Person-Centered Service Plan (PCSP), and performing ongoing monitoring through face-to-face and telephonic contacts. The service spans multiple waivers, including the Consolidated, Community Living, and Person/Family Directed Support (P/FDS) waivers under ODP, and the Community HealthChoices (CHC) waiver under OLTL.
- Service Nomenclature: Supports Coordination (HCBS waivers) or Targeted Support Management (State Plan).
- Core Functions: Assessment, ISP/PCSP development, service referral, and ongoing participant monitoring.
- ODP Target Population: Individuals with intellectual disabilities, autism, and developmental disabilities.
- OLTL Target Population: Seniors and adults with physical disabilities requiring nursing facility level of care.
- Delivery Setting: Community-based, requiring travel to the participant's home, day program, or community setting.
- Conflict-Free Requirement: Supports Coordination Organizations (SCOs) cannot provide direct waiver services to the same individuals they coordinate.
2. Regulatory and Oversight Agencies
The Pennsylvania Department of Human Services (DHS) is the single state Medicaid agency responsible for overall program administration. Within DHS, specific program offices manage the waivers and oversee Supports Coordination Organizations based on the target population.
The Office of Developmental Programs (ODP) oversees SCOs serving the ID/A populations, while the Office of Long-Term Living (OLTL) oversees those serving aging and physically disabled populations. Medicaid enrollment and claims processing are managed through the PROMISe system.
- State Medicaid Agency: Pennsylvania Department of Human Services (DHS) (https://www.dhs.pa.gov).
- ID/A Oversight: Office of Developmental Programs (ODP) (https://www.dhs.pa.gov/about/Pages/ODP.aspx).
- Aging/Physical Disability Oversight: Office of Long-Term Living (OLTL) (https://www.dhs.pa.gov/about/Pages/OLTL.aspx).
- Medicaid Enrollment Portal: PROMISe Provider Portal (https://promise.dhs.pa.gov).
- Local Oversight (ODP): County Administrative Entities (AEs) which manage local waiver capacity and provider agreements.
3. Gatekeeping Prerequisites: Who Can Even Apply
Pennsylvania does not utilize a Certificate of Need (CON) program for Supports Coordination, but it enforces strict structural prerequisites before a PROMISe enrollment application is accepted. For ODP waivers, an applicant must first complete the ODP New Provider Orientation and submit a New Provider Qualification packet; PROMISe will reject applications lacking the ODP approval letter.
For OLTL waivers operating under the Community HealthChoices (CHC) managed care model, PROMISe enrollment alone does not guarantee the ability to bill. Providers must secure credentialing and contracts with the designated CHC-MCOs (e.g., UPMC, PA Health & Wellness, AmeriHealth Caritas), which frequently enforce closed networks due to network adequacy standards.
- ODP Prerequisite: Mandatory completion of the ODP New Provider Orientation before submitting a qualification packet.
- ODP Qualification Approval: Must obtain an approved Provider Qualification letter from ODP prior to PROMISe enrollment.
- OLTL MCO Contracting: Must secure network contracts with regional CHC-MCOs to receive referrals and reimbursement.
- MCO Network Adequacy: CHC-MCOs may deny credentialing if they determine their current SCO network is adequate for the region.
- County AE Agreement: ODP providers must establish an operating agreement with the local county Administrative Entity (AE).
- Conflict-Free Status: The applying entity must be structurally separate from direct HCBS service provision to comply with CMS conflict-free case management rules.
4. Licensure and Certification Requirements
Pennsylvania does not license Supports Coordination Organizations under a distinct facility or agency licensure authority. Instead, providers are approved through a certification and qualification process governed by state regulations.
ODP providers must comply with 55 Pa. Code Chapter 51 (Office of Developmental Programs Home and Community-Based Services). OLTL providers must comply with 55 Pa. Code Chapter 52 (Long-Term Living Home and Community-Based Services). Compliance is verified through the initial qualification application and subsequent state or MCO audits.
- Licensure Status: No distinct state license exists; operating authority is granted via Provider Qualification.
- ODP Regulatory Authority: 55 Pa. Code Chapter 51 governs ID/A waiver provider requirements.
- OLTL Regulatory Authority: 55 Pa. Code Chapter 52 governs aging and physical disability waiver provider requirements.
- Qualification Renewal: ODP requires providers to requalify every three years to maintain active status.
- Business Registration: Must be registered to do business in Pennsylvania with the Department of State.
5. Medicaid Provider Enrollment
Once the prerequisite qualification is obtained, the agency must enroll as a billing provider through the PROMISe Provider Portal. The application requires the submission of the qualification letter, ownership disclosures, and an active National Provider Identifier (NPI).
Upon initiating a new application in PROMISe, the system generates an Application Tracking Number (ATN). Providers must retain this ATN to track their application status, as the portal does not allow users to save and return to an incomplete application later.
- Enrollment Portal: PROMISe Provider Portal (https://promise.dhs.pa.gov).
- Provider Type: Enrolls under specific Provider Types and Specialties corresponding to Supports Coordination (e.g., PT 21).
- Application Tracking Number (ATN): A unique identifier generated at the start of the PROMISe application used for status tracking.
- Required Documentation: IRS W-9, NPI assignment letter, and ODP/OLTL qualification approval letter.
- Application Fee: Subject to the ACA institutional provider application fee unless waived by Medicare or another state's Medicaid program.
- Revalidation: Providers must revalidate their PROMISe enrollment every five years.
6. Staffing, Training and Background Checks
The Pennsylvania DHS classifies Supports Coordination as a "high" categorical risk level for Medicaid enrollment. This requires all persons with a 5% or greater ownership interest, as well as managing employees, to undergo extensive background checks, including FBI fingerprinting.
Direct-care Supports Coordinators must meet specific educational and experience thresholds, typically requiring a Bachelor's degree. Agencies must also maintain a designated Supports Coordinator Supervisor to oversee the clinical and administrative functions of the SC staff.
- Risk Category: Classified as "high" categorical risk per MA Bulletin 99-17-03.
- Background Checks: Requires Federal Bureau of Investigation (FBI) fingerprint check and Pennsylvania State Police Criminal Record Check.
- SC Qualifications: Generally requires a Bachelor's degree in a human services field, or a Bachelor's degree with supplemental human services experience.
- Supervisor Ratio: Agencies must maintain a compliant ratio of SC Supervisors to frontline Supports Coordinators.
- Mandatory Training: Staff must complete state-mandated training modules on incident management, person-centered planning, and the HCBS Settings Rule.
- Child Abuse Clearance: Required for staff interacting with participants under the age of 18.
7. Documentation, Policies and Records
Approved SCOs must maintain comprehensive policy manuals that align with Chapter 51 or Chapter 52 regulations. These policies must be submitted during the qualification phase and implemented immediately upon approval.
Critical documentation includes a formal Quality Management (QM) Plan, an Incident Management policy utilizing the Enterprise Incident Management (EIM) system, and detailed protocols for conflict-free case management and participant rights.
- Quality Management Plan: Must develop and implement a QM plan that tracks performance metrics and participant outcomes.
- Incident Management: Policies must dictate reporting timelines and procedures using the state's EIM system.
- Record Retention: Participant and billing records must be retained for a minimum of five years, or longer if under audit.
- Emergency Disaster Plan: Must maintain a continuity of operations plan for natural disasters or public health emergencies.
- Conflict of Interest Policy: Written policies demonstrating structural and operational separation from direct service provision.
8. Billing, Rates and Claims
Supports Coordination is billed in 15-minute increments using specific HCPCS procedure codes (e.g., T1016 or T2024) depending on the waiver and target population. Claims for ODP services are processed through PROMISe, while OLTL claims are submitted directly to the contracted CHC-MCOs.
For ODP, service authorization and ISP data are managed within the Home and Community Services Information System (HCSIS). Providers cannot bill for services unless the ISP is approved in HCSIS and the units are authorized.
- Billing Increments: Services are typically billed in 15-minute units.
- ODP Claims System: Billed directly to DHS via the PROMISe portal.
- OLTL Claims System: Billed to the participant's assigned CHC-MCO clearinghouse.
- Authorization System: HCSIS (Home and Community Services Information System) is used for ODP service authorizations.
- Rate Setting: Fee-for-service rates are established by DHS and published in the Pennsylvania Bulletin.
- Non-Billable Activities: Travel time and administrative supervision are generally built into the rate and not billed separately.
9. Approval Sequence and Timeline
The pathway to becoming a billable SCO in Pennsylvania is strictly sequential. An entity must first establish its corporate structure and complete the required state orientation before submitting the provider qualification packet to ODP or OLTL.
Only after the state issues the qualification approval letter can the agency submit its PROMISe enrollment application. For OLTL providers, PROMISe enrollment is followed by the MCO credentialing and contracting phase, which can add several months to the timeline.
- Step 1: Corporate formation and obtaining an NPI and EIN.
- Step 2: Completion of ODP New Provider Orientation (if applicable).
- Step 3: Submission and approval of the Provider Qualification packet (30-90 days).
- Step 4: Submission of the PROMISe Medicaid enrollment application (30-60 days).
- Step 5: CHC-MCO credentialing and contracting for OLTL providers (90-120 days).
- Step 6: Execution of county AE agreements for ODP providers.
10. Common Denials and Survey Findings
Applications are frequently rejected at the PROMISe enrollment stage if the provider fails to include the required ODP or OLTL qualification letter, or if the high-risk background checks for owners and managing employees are incomplete.
During post-enrollment audits, state surveyors commonly cite SCOs for failing to complete required face-to-face monitoring visits within the mandated timeframes, or for employing Supports Coordinators who do not meet the strict degree and experience requirements.
- Missing Qualification: PROMISe applications denied for lacking the prerequisite ODP/OLTL approval letter.
- Background Check Failures: Denials due to missing FBI or State Police clearances for 5% owners.
- ATN Loss: Applications abandoned because the provider failed to record the Application Tracking Number and timed out.
- Monitoring Deficiencies: Audit citations for missed or late quarterly face-to-face participant visits.
- Personnel File Gaps: Citations for missing degree transcripts or required training certificates in SC personnel files.
- MCO Network Closure: OLTL providers fully enrolled in PROMISe but denied MCO contracts due to network adequacy.
11. Key Contacts and Resources
Prospective providers must utilize the official DHS portals and help desks to navigate the qualification and enrollment processes. The PROMISe portal serves as the central hub for Medicaid enrollment applications and fee-for-service claims.
For program-specific guidance, providers should reference the ODP or OLTL provider pages on the DHS website, which house the current waiver appendices, rate schedules, and provider bulletins.
- DHS Provider Enrollment: 1-800-537-8862 for PROMISe application assistance.
- PROMISe Portal: https://promise.dhs.pa.gov
- ODP Provider Resources: https://www.dhs.pa.gov/providers/Providers/Pages/ODP-Providers.aspx
- OLTL Provider Resources: https://www.dhs.pa.gov/providers/Providers/Pages/OLTL-Providers.aspx
- Change of Ownership (CHOW): Inquiries directed to [email protected].
- Pennsylvania Code: https://www.pacodeandbulletin.gov for Chapter 51 and Chapter 52 regulations.
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