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

Last reviewed: 2026-09-10

The Pennsylvania Department of Human Services (DHS) Office of Developmental Programs (ODP) funds structured daytime programming under the service name Community Participation Support (CPS), formerly and interchangeably referred to as Day Habilitation, through the Consolidated, Person/Family Directed Support (P/FDS), and Community Living waivers.

Prospective providers must complete the mandatory ODP Provider Applicant Orientation and obtain a facility license under 55 Pa. Code Chapter 2380 (Adult Training Facilities) or Chapter 2390 (Vocational Facilities) before submitting a New Provider Qualification application to their regional Administrative Entity (AE).

1. Service Definition and Scope

In Pennsylvania, Day Habilitation is primarily delivered as Community Participation Support (CPS). This service provides opportunities for community inclusion and builds interest in and develops skills for potential employment.

Services can be provided in licensed facilities or integrated community settings, with a strong regulatory push toward community-based delivery to comply with the HCBS Settings Rule.

• Service Name: Community Participation Support (CPS) / Day Habilitation.
• Target Population: Individuals enrolled in the Consolidated, P/FDS, or Community Living waivers.
• Setting Requirements: Must comply with the HCBS Settings Rule; facilities cannot be adjacent to ICF/IDs or located on campus settings.
• Duration Limits: A participant may be authorized for a maximum of 14 hours per day of combined day services (e.g., CPS, In-Home and Community Support) under the Consolidated Waiver.
• Service Modifiers: Procedure codes must specify whether services are rendered in integrated community settings or facility settings.

2. Regulatory and Oversight Agencies

The Pennsylvania Department of Human Services (DHS) is the single state Medicaid agency. Within DHS, the Office of Developmental Programs (ODP) operates the waivers that fund CPS.

Facility licensure is managed by the DHS Bureau of Human Services Licensing (BHSL), while Medicaid enrollment is processed through the Office of Medical Assistance Programs (OMAP).

• Primary Agency: Pennsylvania Department of Human Services (DHS) (https://www.pa.gov/agencies/dhs.html)
• Operating Agency: Office of Developmental Programs (ODP) (https://www.myodp.org)
• Licensing Division: DHS Bureau of Human Services Licensing (BHSL) (https://www.pa.gov/agencies/dhs/resources/for-providers/licensing.html)
• Medicaid Enrollment Portal: PROMISe Provider Portal (https://promise.dhs.pa.gov/portal/provider/Home/tabid/135/Default.aspx)

3. Gatekeeping Prerequisites: Who Can Even Apply

Pennsylvania imposes strict sequential prerequisites for new ODP providers. An applicant cannot simply submit a Medicaid enrollment application without prior approvals.

The process is gated by mandatory training, facility licensure, and regional qualification through a county Administrative Entity (AE).

• Mandatory Training: Completion of the ODP Provider Applicant Orientation via MyODP is required before any application is accepted.
• Facility Licensure: Providers operating facility-based CPS must hold an active Chapter 2380 or 2390 license before Medicaid enrollment.
• Local Qualification: Applicants must submit their New Provider Qualification documentation to the local county Administrative Entity (AE) for review.
• Settings Compliance: New facilities must be approved by ODP utilizing the residential/day setting criteria to ensure they are not adjacent to institutional settings.

4. Licensure and Certification Requirements

Facility-based day services in Pennsylvania require a specific license from the DHS Bureau of Human Services Licensing.

Providers must maintain compliance with state code and undergo regular inspections and quality assessments.

• Adult Training Facilities: Licensed under 55 Pa. Code Chapter 2380.
• Vocational Facilities: Licensed under 55 Pa. Code Chapter 2390.
• Inspection Cycle: ODP maintains information about each licensed facility to ensure an annual licensing inspection is completed.
• Quality Assessment: Providers are monitored through the ODP Quality Assessment and Improvement (QA&I) process once every three years.

5. Medicaid Provider Enrollment

Once licensed and qualified by the AE, providers must enroll in the Pennsylvania Medicaid program via the PROMISe Provider Portal.

CPS providers are subject to high-risk screening requirements under the Affordable Care Act.

• Enrollment System: PROMISe Provider Portal.
• Application Tracking: An Application Tracking Number (ATN) is assigned when a New Application is started and must be retained.
• Risk Category: DHS assigns these provider types to the "high" categorical risk level.
• Ownership Screening: Any person with a 5% or greater direct or indirect ownership interest must submit criminal background check information.

6. Staffing, Training and Background Checks

Direct support professionals providing CPS must meet qualifications outlined in the approved waiver appendices and state regulations.

Because of the high-risk categorical designation, extensive background clearances are mandatory.

• Federal Clearance: Federal Bureau of Investigation (FBI) criminal background check required for staff and 5% owners.
• State Clearance: Pennsylvania State Police Criminal Record Check required.
• Child Abuse Clearance: PA Child Abuse History Clearance required if the provider serves individuals under 18.
• Training Requirements: Staff must complete annual training as specified in Chapter 2380/2390 and ODP bulletins.

7. Documentation, Policies and Records

Providers must maintain comprehensive records to support billing and demonstrate compliance with ODP regulations.

Services must be explicitly authorized in the participant's plan before delivery.

• Service Authorization: The CPS service, provider, and location must be authorized on each person’s Individual Support Plan (ISP).
• Progress Notes: Daily documentation must reflect activities, community integration, and progress toward ISP goals.
• Incident Management: Providers must maintain and follow written policies for incident management and reporting via the Enterprise Incident Management (EIM) system.
• Record Retention: Financial and programmatic records must generally be retained for a minimum of five years.

8. Billing, Rates and Claims

Reimbursement for CPS is processed through the PROMISe system based on a statewide fee schedule established by ODP.

Rates vary depending on the staff-to-individual ratio and whether the service is provided in a facility or a community setting.

• Billing System: Claims are submitted through the PROMISe Provider Portal.
• Rate Setting: ODP publishes the fee schedule rates for Consolidated, P/FDS, and Community Living waivers via provider bulletins.
• Procedure Codes: Specific HCPCS codes and modifiers are used to distinguish between facility-based and community-based CPS.
• Unit of Service: Services are typically billed in 15-minute units, subject to daily maximums.

9. Approval Sequence and Timeline

Becoming a CPS provider in Pennsylvania is a multi-phase process that can take several months to complete.

Applicants must follow the exact sequence, as downstream systems require approvals from upstream steps.

• Step 1: Register for and complete the ODP Provider Applicant Orientation on MyODP.
• Step 2: Apply for and obtain a Chapter 2380 or 2390 facility license from BHSL.
• Step 3: Submit the New Provider Qualification application to the regional Administrative Entity (AE).
• Step 4: Upon AE approval, submit the Medicaid enrollment application via the PROMISe portal.

10. Common Denials and Survey Findings

Applications and subsequent licensing surveys often fail due to strict adherence to HCBS Settings rules and background check requirements.

ODP actively monitors for institutional characteristics in day program settings.

• Settings Rule Violations: Applications denied because the proposed facility is adjacent to an ICF/ID or located on a campus.
• Incomplete Clearances: Failure to provide FBI background checks for all individuals with a 5% or greater ownership interest.
• Missing Orientation: Attempting to submit qualification documents without the MyODP Applicant Orientation certificate.
• ISP Mismatch: Survey findings for billing services or ratios not explicitly authorized in the participant's ISP.

11. Key Contacts and Resources

Providers should rely on official DHS and ODP portals for the most current regulations, bulletins, and training materials.

The PROMISe portal and MyODP are the primary operational hubs for PA waiver providers.

• ODP Training Portal: MyODP (https://www.myodp.org)
• Medicaid Enrollment Portal: PROMISe (https://promise.dhs.pa.gov/portal/provider/Home/tabid/135/Default.aspx)
• Provider Enrollment Help: OMAP Department of Provider Enrollment at 1-800-537-8862
• Licensing Regulations: Pennsylvania Code Chapters 2380 and 2390 (http://www.pacodeandbulletin.gov)

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