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

Last reviewed: 2026-08-16

In Pennsylvania, Day Habilitation is a Medicaid Home and Community-Based Services (HCBS) waiver service administered by the Office of Developmental Programs (ODP). It provides structured, non-residential daytime programming to help individuals with intellectual disabilities and autism acquire, retain, and improve self-help, socialization, and adaptive skills necessary for community integration.

The single biggest structural barrier to entry for this service in Pennsylvania is the mandatory ODP New Provider Qualification process. Before an applicant is even permitted to submit a Medicaid enrollment application or bill for services, they must complete a mandatory Applicant Orientation and pass a rigorous New Provider Self-Assessment, which requires submitting a fully developed, compliant policy manual to ODP for approval.

1. Service Definition and Scope

Day Habilitation in Pennsylvania is defined as an ODP waiver service provided in non-residential settings to assist participants in building essential life skills. It is typically delivered in licensed Adult Training Facilities, though it can include community-based integration activities.

The service is designed to prevent institutionalization by fostering independence. It cannot be billed concurrently with residential habilitation or supported employment for the same hours of service.

• Target Population: Individuals with intellectual disabilities or autism enrolled in ODP waivers, including the Consolidated, Community Living, and Person/Family Directed Support (P/FDS) waivers.
• Service Settings: Primarily delivered in licensed Adult Training Facilities governed by 55 Pa. Code Chapter 2380, or in integrated community hubs.
• Core Activities: Skill-building in activities of daily living (ADLs), socialization, communication, and community integration.
• Exclusions: Cannot be provided or billed during the same time a participant is receiving Supported Employment, Prevocational Services, or Residential Habilitation.
• Service Limits: Authorized hours are strictly dictated by the participant's Individual Support Plan (ISP) developed by their Supports Coordinator.

2. Regulatory and Oversight Agencies

The Pennsylvania Department of Human Services (DHS) is the state Medicaid agency responsible for overall program administration. Within DHS, two distinct divisions handle the approval of Day Habilitation providers.

The Office of Developmental Programs (ODP) manages the HCBS waivers and provider qualifications, while the Bureau of Human Services Licensing (BHSL) conducts physical site inspections and issues facility licenses.

• State Medicaid Agency: Pennsylvania Department of Human Services (DHS) (https://www.pa.gov/agencies/dhs)
• Waiver Operating Agency: Office of Developmental Programs (ODP) (https://www.pa.gov/agencies/dhs/resources/for-providers/developmental-programs-for-providers)
• Licensing Authority: DHS Bureau of Human Services Licensing (BHSL) (https://www.pa.gov/agencies/dhs/resources/licensing)
• Medicaid Enrollment Portal: PROMISe (Provider Reimbursement and Operations Management Information System) (https://promise.dpw.state.pa.us)
• Training and Resource Portal: MyODP (https://www.myodp.org)

3. Gatekeeping Prerequisites: Who Can Even Apply

Pennsylvania does not require a Certificate of Need (CON) or an RFP/procurement contract for Day Habilitation services. However, the state enforces a strict, sequential gatekeeping process that blocks Medicaid enrollment until specific ODP prerequisites are met.

Providers cannot submit an application to the PROMISe Medicaid portal until they have successfully completed the ODP Applicant Orientation and received an approved New Provider Qualification status from ODP.

• Certificate of Need (CON): None exists or is required for Day Habilitation facilities in Pennsylvania.
• Mandatory Orientation: Applicants must register for and complete the ODP Provider Applicant Orientation before initiating the qualification process.
• ODP Provider Qualification: Applicants must submit and pass the ODP New Provider Self-Assessment, proving compliance with waiver Appendix C standards through vetted policies.
• Corporate Registration: Must possess approved formation documents from the Pennsylvania Department of State and a Federal Employer Identification Number (FEIN).
• Commercial Insurance: Must secure general liability and worker's compensation insurance prior to ODP qualification approval.
• Managed Care Contracting: Not required for ODP waiver Day Habilitation, which operates under a fee-for-service model rather than through physical health Managed Care Organizations (MCOs).

4. Licensure and Certification Requirements

Facility-based Day Habilitation requires licensure as an Adult Training Facility under 55 Pa. Code Chapter 2380. Providers must submit an Application for Certificate of Compliance to the DHS Bureau of Human Services Licensing (BHSL).

The licensing process includes a rigorous physical site inspection to ensure compliance with fire safety, accessibility, and the CMS HCBS Settings Rule regarding community integration.

• Licensure Rule: 55 Pa. Code Chapter 2380 (Adult Training Facilities).
• Application Form: DHS Application for Certificate of Compliance (Form HS 633).
• Fire Safety Approval: Must obtain a Certificate of Occupancy approved under the Pennsylvania Uniform Construction Code (UCC) specifically designating the building for facility use.
• HCBS Settings Rule: Facilities must demonstrate compliance with CMS final rule requirements for privacy, dignity, and community integration, verified during the BHSL inspection.
• Fictitious Name Approval: If operating under a DBA, a copy of the PA Department of State's approved fictitious name papers must be included with Form HS 633.
• License Renewal: The Certificate of Compliance must be renewed annually following a successful BHSL survey.

5. Medicaid Provider Enrollment

After obtaining ODP qualification and the Chapter 2380 license, providers must enroll in the Pennsylvania Medicaid program via the PROMISe portal. Enrollment is processed by the DHS Office of Medical Assistance Programs (OMAP).

Because Day Habilitation is an HCBS waiver service, providers must enroll under specific provider types and specialties that match their ODP qualification.

• Enrollment System: PROMISe electronic provider enrollment portal.
• Provider Type: Must enroll as Provider Type 51 (HCBS Waiver Provider) with the specific specialty code for Day Habilitation.
• Application Fee: Subject to the ACA institutional provider application fee (approximately $731 for 2024) unless waived by prior Medicare enrollment.
• Site Visits: Subject to pre-enrollment site visits by DHS, as HCBS providers fall under moderate or high-risk screening categories.
• Required Attachments: Must upload the ODP Qualification letter and the BHSL Chapter 2380 Certificate of Compliance directly into the PROMISe application.
• Revalidation: Required every 5 years through the PROMISe system to maintain active billing status.

6. Staffing, Training and Background Checks

Pennsylvania regulations under Chapter 2380 dictate strict staffing hierarchies and ratios for Adult Training Facilities. Agencies must employ a Chief Executive Officer, a Program Specialist, and Direct Support Professionals (DSPs).

All staff must clear rigorous background checks before having direct contact with participants, and they must complete state-mandated training modules annually.

• Program Specialist Qualifications: Requires a master's degree and 1 year of experience, or a bachelor's degree and 2 years of experience working with individuals with disabilities.
• Direct Care Staff: Must be at least 18 years old, possess a high school diploma or GED, and complete required training before working independently.
• Staffing Ratios: Minimum 1 direct care staff for every 6 individuals (1:6) during active programming, though this must be adjusted based on the specific needs outlined in participants' ISPs.
• Background Checks: Pennsylvania State Police criminal history clearance required for all staff; FBI clearance required if the applicant lived outside PA in the past 2 years.
• Child Abuse Clearance: Required under the PA Child Protective Services Law if the facility serves any individuals under 18 years of age.
• Mandatory Training: Annual training required on abuse/neglect reporting (Incident Management), ISP implementation, and positive intervention strategies.

7. Documentation, Policies and Records

ODP requires a comprehensive suite of policies to be submitted during the qualification phase and maintained on-site. Client records must strictly align with the Individual Support Plan (ISP) developed by the Supports Coordinator.

Facilities must also maintain robust emergency preparedness documentation and incident management logs to satisfy BHSL licensing surveyors.

• Quality Management Plan: Must develop and implement an ODP-approved Quality Management (QM) plan that is evaluated and updated annually.
• Incident Management Policy: Must align with ODP Bulletin requirements for reporting critical incidents within 24 hours via the Enterprise Incident Management (EIM) system.
• Client Records: Must maintain daily attendance logs, progress notes tied directly to ISP goals, and quarterly review summaries.
• Emergency Preparedness: Must have a written disaster response plan and conduct documented fire drills at least once a month under Chapter 2380 regulations.
• Rights Documentation: Must maintain signed documentation that participants were educated on and understand their rights under the HCBS Settings Rule.
• Record Retention: Medicaid records must be retained for a minimum of 5 years from the date of service or claim submission.

8. Billing, Rates and Claims

Day Habilitation is billed through the PROMISe system using standard HIPAA-compliant 837P transactions or direct data entry. ODP establishes fee schedule rates that are uniform across the state.

Providers can only bill for services that have been explicitly authorized on the participant's ISP by the Supports Coordination Organization (SCO).

• Billing System: Claims are submitted electronically to the PROMISe MMIS.
• Reimbursement Methodology: Paid according to the ODP Fee Schedule, typically billed in 15-minute units using specific HCPCS codes (e.g., W7100 or similar, depending on the waiver).
• Prior Authorization: Services must be authorized on the participant's ISP by the SCO before any billing can occur.
• EVV Exemption: Facility-based Day Habilitation is generally exempt from Electronic Visit Verification (EVV), which applies primarily to in-home personal care services.
• Timely Filing: Claims must be submitted within 180 days of the date of service to avoid denial.
• Attendance Documentation: Billing must be supported by daily attendance records signed by the direct care staff providing the service.

9. Approval Sequence and Timeline

The end-to-end process for becoming a Day Habilitation provider in Pennsylvania typically takes 6 to 9 months. It requires sequential approvals from ODP, BHSL, and OMAP.

Providers cannot skip steps; the BHSL license requires ODP qualification, and PROMISe enrollment requires both the ODP qualification and the BHSL license.

• Step 1: Register for and complete the ODP Applicant Orientation (typically takes 1 month to schedule and complete).
• Step 2: Submit the New Provider Self-Assessment and policy manual to ODP for qualification (60-90 days for review and approval).
• Step 3: Submit Form HS 633 to BHSL to initiate Chapter 2380 Adult Training Facility licensure (90-120 days, including physical site inspection).
• Step 4: Submit the PROMISe Medicaid Enrollment application with ODP and BHSL approvals attached (30-60 days for OMAP processing).
• Step 5: Receive PROMISe Provider ID and begin accepting participant referrals from Supports Coordinators.

10. Common Denials and Survey Findings

Applications are frequently delayed during the ODP qualification phase due to incomplete or generic policy manuals. ODP validates that written policies genuinely meet Pennsylvania-specific standards.

During BHSL licensing surveys, physical plant issues and documentation gaps are the most common citations that delay the issuance of a Certificate of Compliance.

• Policy Rejections: Failing the ODP Self-Assessment because policies lack specific PA regulatory citations or required HCBS settings language.
• Zoning/Occupancy Issues: Submitting a Certificate of Occupancy that does not explicitly approve the building for Adult Training Facility or commercial assembly use.
• Background Check Gaps: Allowing staff to begin orientation or direct care before the PA State Police or FBI clearances are fully returned and cleared.
• ISP Non-Compliance: Citations for failing to document how daily facility activities directly link to the specific goals outlined in the participant's ISP.
• Fire Safety Violations: Missing documentation for monthly fire drills or failing to maintain clear, unobstructed egress routes during BHSL inspections.
• PROMISe Denials: Having the Medicaid enrollment application rejected for failing to pay the ACA application fee or failing to upload the required BHSL license.

11. Key Contacts and Resources

Providers should rely on the official DHS and ODP portals for the most current bulletins, fee schedules, and training requirements. The MyODP portal is essential for ongoing staff and administrative compliance.

For licensing questions, the BHSL regional offices are the primary point of contact for physical site requirements and Form HS 633 submissions.

• PA Department of Human Services (DHS): https://www.pa.gov/agencies/dhs
• Office of Developmental Programs (ODP): https://www.pa.gov/agencies/dhs/resources/for-providers/developmental-programs-for-providers
• DHS Bureau of Human Services Licensing (BHSL): https://www.pa.gov/agencies/dhs/resources/licensing
• MyODP Training and Resource Portal: https://www.myodp.org
• PROMISe Provider Portal: https://promise.dpw.state.pa.us
• ODP Customer Service Line: 1-888-565-9435 or RA-customerservice@pa.gov

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