Pennsylvania - Case Management Service — Licensing, Medicaid Enrollment and Startup Requirements
Last reviewed: 2026-08-16
In Pennsylvania, Case Management for Medicaid Home and Community-Based Services (HCBS) is primarily referred to as Service Coordination. This service involves comprehensive assessment, person-centered service plan development, referral, and ongoing monitoring of a participant's full service package. The service is administered primarily through two divisions of the Department of Human Services (DHS): the Office of Developmental Programs (ODP) for individuals with intellectual disabilities and autism, and the Office of Long-Term Living (OLTL) for aging individuals and those with physical disabilities.
The single biggest structural barrier to entry for this service in Pennsylvania is the strict enforcement of Conflict-Free Case Management (CFCM) combined with Managed Care network restrictions. Under ODP, an agency is structurally barred from enrolling if it intends to provide both direct HCBS waiver services and Service Coordination to the same individuals. Under OLTL's Community HealthChoices (CHC) program, enrolling with the state is not enough; providers face a closed-network managed care gate and must secure contracts with specific regional Managed Care Organizations (MCOs) to receive referrals and bill for services.
1. Service Definition and Scope
Pennsylvania defines this service as Service Coordination under its HCBS waivers and Targeted Case Management (TCM) under the Medicaid State Plan. The core function is to assist participants in gaining access to needed waiver services, Medicaid State Plan services, and other medical, social, and educational services regardless of the funding source.
Service Coordinators are responsible for facilitating the person-centered planning process, developing the Individual Support Plan (ISP) or Person-Centered Service Plan (PCSP), and conducting ongoing monitoring to ensure services are delivered in accordance with the plan and the CMS HCBS Settings Rule.
- Terminology: Officially designated as Service Coordination in PA HCBS waivers (Consolidated, P/FDS, Community Living, and CHC) and Targeted Case Management (TCM) in the State Plan.
- Core Function: Comprehensive assessment, development of the Individual Support Plan (ISP), and continuous monitoring of service delivery.
- Target Populations: Individuals with intellectual disabilities and autism (managed by ODP) or aging adults and individuals with physical disabilities (managed by OLTL).
- Conflict-Free Mandate: Providers are prohibited from providing both Service Coordination and direct waiver services (like residential or day habilitation) to the same participant.
- Settings Rule Compliance: Service Coordinators are the primary mechanism for monitoring ongoing provider compliance with the CMS HCBS Settings Rule during their face-to-face visits.
2. Regulatory and Oversight Agencies
The Pennsylvania Department of Human Services (DHS) is the single state Medicaid agency responsible for all HCBS programs. Oversight is bifurcated based on the target population served by the specific waiver.
ODP manages the intellectual disability and autism waivers, while OLTL manages the aging and physical disability waivers, primarily through the Community HealthChoices (CHC) managed care model.
- Primary 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/DHS-Information/Pages/Office-of-Developmental-Programs.aspx)
- Aging/Physical Disabilities Oversight: Office of Long-Term Living (OLTL) (https://www.dhs.pa.gov/about/DHS-Information/Pages/Office-of-Long-Term-Living.aspx)
- Medicaid Enrollment Portal: PROMISe Provider Portal (https://promise.dpw.state.pa.us)
- Managed Care Oversight: Community HealthChoices (CHC) MCOs, such as PA Health & Wellness (https://www.pahealthwellness.com)
- Training and Qualification Portal: MyODP (https://www.myodp.org)
3. Gatekeeping Prerequisites: Who Can Even Apply
Pennsylvania does not require a Certificate of Need for case management, but it enforces severe structural preconditions before an application is accepted. Providers must clear specific programmatic gates depending on whether they are applying under ODP or OLTL.
For ODP, the state enforces a strict orientation and qualification timeline. For OLTL, the transition to Managed Long-Term Services and Supports (MLTSS) means that state enrollment is entirely subordinate to MCO network contracting.
- Conflict-Free Case Management (CFCM): Applicants must legally, financially, and operationally separate service coordination from direct HCBS provision; ODP will reject applications from entities providing direct waiver services.
- ODP Applicant Orientation: Mandatory prerequisite for ID/A waivers; applicants must register for, attend, and pass the ODP Applicant Orientation to receive a Certificate of Completion before applying.
- 120-Day Qualification Window: The ODP Orientation Certificate of Completion expires if the provider does not successfully complete the Provider Qualification process within 120 days.
- MLTSS MCO Contracting: For OLTL Community HealthChoices, providers must secure credentialing and contracts with regional CHC MCOs (e.g., UPMC, AmeriHealth Caritas, PA Health & Wellness); without an MCO contract, a provider cannot operate in the CHC program.
- Business Registration: Applicants must be registered with the Pennsylvania Department of State as a legal business entity authorized to operate in the Commonwealth.
4. Licensure and Certification Requirements
Pennsylvania does not issue a traditional facility or agency license for Case Management or Service Coordination through the DHS Bureau of Human Services Licensing. There is no specific PA Code licensing chapter (like Chapter 6400 for group homes) that applies to this service.
Instead, agencies must achieve "Provider Qualification" status directly from the operating program office (ODP or OLTL). This process acts as the functional equivalent of licensure, requiring the submission of policies, procedures, and organizational charts to prove capability.
- Licensure Exemption: No physical facility license is issued or required by the DHS Bureau of Human Services Licensing for Service Coordination agencies.
- ODP Provider Qualification: Agencies must submit the DP 1059 form (Provider Qualification form) and supporting operational policies to their assigned Administrative Entity (AE) or ODP regional office.
- OLTL Qualification: Agencies must complete the OLTL standard application form, which includes specific attestations regarding compliance with the CMS HCBS Final Rule.
- Policy Review: Applicants must submit their Quality Management Plan, Conflict-Free policies, and Incident Management policies for state review prior to approval.
- HCBS Settings Rule Attestation: Providers must submit documentation proving their person-centered planning policies align with the federal HCBS Settings Rule.
5. Medicaid Provider Enrollment
Once Provider Qualification is achieved through ODP or OLTL, the agency must enroll in the Pennsylvania Medical Assistance program. This is done electronically through the PROMISe (Provider Reimbursement and Operations Management Information System) portal.
Providers must select the correct Provider Type and Specialty codes that correspond to Service Coordination for their specific target population, and upload their qualification approvals as attachments.
- System: PROMISe Provider Portal (https://promise.dpw.state.pa.us).
- Provider Type: Typically enrolled under Provider Type 21 (Case Manager) with specific waiver specialty codes (e.g., Specialty 081 for Service Coordination).
- Application Pathway: Electronic submission via the PROMISe portal using the "New Application" function.
- Required Identifiers: Must supply a National Provider Identifier (NPI), FEIN, and a taxonomy code matching case management/service coordination.
- Application Fee: Subject to the federal Medicaid/Medicare application fee (approximately $709 for 2024/2025) unless waived due to prior Medicare enrollment or enrollment in another state.
- Revalidation: Providers must revalidate their Medicaid enrollment through the PROMISe system every 5 years.
6. Staffing, Training and Background Checks
Staffing qualifications for Service Coordinators are strictly defined in the approved 1915(c) waiver appendices and 55 Pa. Code Chapter 1247. Agencies must ensure all staff meet educational minimums before they bill for any services.
Pennsylvania also enforces strict background check requirements, including state and federal criminal history clearances and child abuse clearances where applicable.
- Education Minimums: Must possess a Bachelor's degree in sociology, social work, psychology, gerontology, or a related social science field, OR hold a valid Registered Nurse (RN) license in Pennsylvania.
- Experience Requirements: Typically requires at least one year of professional experience working directly with the target population (e.g., individuals with intellectual disabilities or aging adults).
- Criminal Clearances: Mandatory Pennsylvania State Police Criminal Record Check and FBI fingerprint-based background check for all client-facing staff.
- Child Abuse Clearance: Pennsylvania Child Abuse History Clearance is mandatory if the Service Coordinator will serve any waiver participants under the age of 21.
- Exclusion Screening: Agencies must screen all staff and owners monthly against the federal LEIE, SAM, and the Pennsylvania Medicheck list.
- Mandatory Training: Staff must complete state-mandated Service Coordination training modules (e.g., via MyODP) within the first 90 days of employment and annually thereafter.
7. Documentation, Policies and Records
Service Coordination agencies must maintain comprehensive records that prove active, ongoing monitoring of the participant's health, safety, and service delivery. The Individual Support Plan (ISP) is the central governing document.
The state requires specific frequencies for face-to-face and telephone contacts, and all interactions must be documented in the state's designated IT systems.
- Person-Centered Planning: Policies must dictate how the agency facilitates participant-led ISP development, ensuring the participant chooses their services and settings.
- Contact Frequency: Documentation must prove adherence to waiver-specific contact rules (e.g., quarterly face-to-face visits and monthly telephone contacts).
- Critical Incident Reporting: Mandatory use of the Enterprise Incident Management (EIM) system to report critical incidents (abuse, neglect, exploitation, hospitalization) within 24 hours of discovery.
- Record Retention: Pennsylvania requires all Medicaid and waiver service records to be retained for a minimum of 5 years.
- Quality Management Plan: Agencies must maintain an active, written Quality Management (QM) plan that is reviewed and updated at least every 2 years.
- Service Notes: Progress notes must include the date, start and end times, location of the visit, individuals present, and a narrative of the participant's progress toward ISP goals.
8. Billing, Rates and Claims
Billing mechanisms in Pennsylvania depend entirely on the waiver program. ODP waiver claims are submitted directly to the state's MMIS (Fee-for-Service), while OLTL CHC claims must be submitted to the contracted Managed Care Organization.
Rates for ODP Service Coordination are standardized and published annually by DHS, whereas CHC rates may be negotiated with the MCOs, though they often mirror the state fee schedule.
- Billing System (ODP): Direct submission to the PROMISe MMIS via 837P electronic transactions or manual entry on the PROMISe internet portal.
- Billing System (OLTL): Claims must be submitted to the specific CHC MCO's clearinghouse (e.g., UPMC, AmeriHealth Caritas, or PA Health & Wellness).
- Procedure Codes: Typically billed using HCPCS code T1016 (Case Management) or T2024 (Service Assessment/Plan of Care) with specific waiver modifiers (e.g., U1, U4).
- Unit Measurement: Service Coordination is usually billed in 15-minute increments.
- Rate Setting: ODP publishes the HCBS fee schedule annually in the Pennsylvania Bulletin; rates are standardized statewide or adjusted by specific geographic regions.
- Third-Party Liability: Medicaid is the payer of last resort; however, Service Coordination is rarely covered by commercial insurance, so TPL bypass rules usually apply.
9. Approval Sequence and Timeline
The end-to-end process for becoming a Service Coordination provider in Pennsylvania can take 4 to 8 months. The timeline is heavily dependent on the provider's speed in completing the mandatory orientation and the state's processing volume.
For OLTL providers, the timeline is extended by the MCO credentialing process, which cannot begin until the PROMISe enrollment is fully approved.
- Step 1: Register for and complete the ODP Applicant Orientation (Certificate valid for 120 days).
- Step 2: Submit Provider Qualification documentation (DP 1059 and policies) to the regional AE or ODP/OLTL office (State review takes 30-60 days).
- Step 3: Submit the PROMISe Medicaid Enrollment application online with qualification attachments (DHS processing takes 45-90 days).
- Step 4: Receive the PROMISe Welcome Letter containing the 13-digit PA MA Provider Number.
- Step 5: (OLTL only) Apply for credentialing and contracting with regional CHC MCOs (Adds 90-120 days to the timeline).
10. Common Denials and Survey Findings
Applications are frequently rejected at the front door for administrative errors, missed deadlines, or failure to meet the strict Conflict-Free Case Management standards. DHS is rigid regarding the 120-day orientation window.
Post-enrollment, the Quality Management Enterprise Team (QMET) monitors compliance. Citations frequently involve failures in documentation or missed monitoring visits.
- 120-Day Expiration: Denials occur when the applicant fails to submit a complete PROMISe application within 120 days of completing the ODP orientation.
- Conflict of Interest: Rejection due to overlapping ownership, shared board members, or shared financial interests between the Service Coordination entity and a direct HCBS provider.
- Incomplete Attachments: Applications returned to provider (RTP) for missing the required Provider Agreement, ownership disclosure forms, or business licenses in the PROMISe portal.
- Monitoring Findings: QMET citations for failing to complete required face-to-face monitoring visits within the exact timeframes specified in the participant's ISP.
- Staff Qualifications: Citations and potential recoupment of funds for deploying Service Coordinators who lack the required degree or experience documentation in their HR file.
- Incident Reporting Failures: Citations for failing to enter critical incidents into the EIM system within the mandatory 24-hour window.
11. Key Contacts and Resources
Providers should rely on the official DHS portals and program office websites for the most current manuals, fee schedules, and enrollment forms. The MyODP portal is essential for ID/A providers.
For OLTL providers, direct communication with the Provider Network Management departments of the CHC MCOs is required for contracting.
- PROMISe Provider Portal: https://promise.dpw.state.pa.us
- DHS Provider Enrollment Information: https://www.dhs.pa.gov/providers/Providers/Pages/PROMISe-Enrollment.aspx
- ODP Provider Qualification & Training: https://www.myodp.org
- OLTL Community HealthChoices: https://www.dhs.pa.gov/HealthChoices/HC-Services/Pages/CHC-Main.aspx
- PA Health & Wellness (CHC MCO): https://www.pahealthwellness.com
- Pennsylvania Code (Regulations): http://www.pacodeandbulletin.gov
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