Pennsylvania - Personal Assistance Services — Licensing, Medicaid Enrollment and Startup Requirements

Last reviewed: 2026-08-16

In Pennsylvania, Personal Assistance Services (PAS) provide essential hands-on help with activities of daily living, such as bathing, dressing, and transferring, allowing individuals to remain in their own homes. Because these are non-medical services, providers are regulated and licensed by the Pennsylvania Department of Health as Home Care Agencies, rather than Home Health Agencies.

The single biggest structural barrier to entry for a new PAS provider in Pennsylvania is securing network contracts with the Community HealthChoices (CHC) Managed Care Organizations (MCOs). While the state does not require a Certificate of Need to obtain a license, Medicaid enrollment alone does not guarantee clients; providers must be accepted into MCO networks, which frequently close to new applicants based on regional network adequacy requirements.

1. Service Definition and Scope

Personal Assistance Services (PAS) in Pennsylvania encompass hands-on assistance with Activities of Daily Living (ADLs) and Instrumental Activities of Daily Living (IADLs). These services are designed to support individuals with physical disabilities or older adults who require long-term services and supports to live safely in community settings.

Under Pennsylvania regulations, PAS is strictly non-medical. Providers delivering these services cannot perform skilled nursing tasks, administer medications, or provide clinical therapies unless they hold a separate Home Health Agency license and employ licensed clinical staff.

• Service Category: Personal Assistance Services (PAS) under the Community HealthChoices (CHC) waiver.
• Licensure Type: Home Care Agency (HCA) non-medical license.
• Covered Tasks: Assistance with ADLs (bathing, transferring, toileting) and IADLs (meal preparation, light housekeeping).
• Setting: The participant's private residence or an approved community setting.
• Exclusions: Skilled nursing, physical therapy, and medication administration are strictly prohibited under a standard HCA license.

2. Regulatory and Oversight Agencies

Oversight of PAS providers in Pennsylvania is divided between the department that issues the physical facility license and the department that manages Medicaid funds. The Department of Health (DOH) ensures compliance with state safety and operational regulations.

The Department of Human Services (DHS) oversees Medicaid enrollment and the waiver programs. Day-to-day administration of the Medicaid HCBS benefits is delegated to Managed Care Organizations (MCOs) under the Community HealthChoices program.

• Licensing Agency: Pennsylvania Department of Health (DOH), Division of Home Health (https://www.health.pa.gov/topics/facilities/home-care/Pages/Home-Care.aspx).
• Medicaid Authority: Pennsylvania Department of Human Services (DHS), Office of Long-Term Living (OLTL) (https://www.dhs.pa.gov/about/Pages/OLTL.aspx).
• Medicaid Portal: PROMISe Provider Enrollment System (https://provider.enrollment.dhs.pa.gov/).
• Managed Care Program: Community HealthChoices (CHC) (https://www.dhs.pa.gov/HealthChoices/Pages/Community-HealthChoices.aspx).
• Designated MCO: PA Health & Wellness (https://www.pahealthwellness.com/providers/become-a-provider.html).
• Designated MCO: UPMC Community HealthChoices (https://www.upmchealthplan.com/providers/chc/).

3. Gatekeeping Prerequisites: Who Can Even Apply

Pennsylvania is highly favorable in terms of initial state planning, as it does not utilize a Certificate of Need (CON) program for home care agencies. Anyone who meets the structural and financial requirements can apply for a Home Care Agency license.

However, the true gatekeeping occurs at the Medicaid contracting level. DHS explicitly states that PROMISe enrollment does not guarantee MCO contracting. Because PAS is delivered through the managed Community HealthChoices (CHC) program, providers must secure contracts with regional MCOs, which frequently enforce closed networks or moratoria based on their own network adequacy assessments.

• Certificate of Need (CON): None required in Pennsylvania for home care agencies, allowing direct application for licensure.
• Licensure Prerequisite: An active PA DOH Home Care Agency license is a strict prerequisite before a Medicaid PROMISe application will be accepted.
• MCO Network Adequacy: CHC MCOs (such as UPMC or PA Health & Wellness) may enforce closed networks, blocking fully licensed and enrolled providers from accessing Medicaid clients.
• Business Registration: Applicants must register their business entity with the Pennsylvania Department of State prior to initiating the DOH application.
• Physical Location: Providers must secure and maintain a commercial office space in Pennsylvania that meets DOH survey standards before applying.

4. Licensure and Certification Requirements

To operate legally, PAS providers must obtain a Home Care Agency license from the Pennsylvania Department of Health. This process is governed by 28 PA Code Chapter 611, which outlines the minimum standards for non-medical home care operations.

The licensure process involves submitting an online application, paying the required fees, and passing a pre-licensure inspection. The agency must have a qualified administrator and comprehensive policies in place before the state surveyor arrives.

• Regulation: 28 PA Code Chapter 611 governs the operation of Home Care Agencies and Home Care Registries.
• Application Method: Submissions must be made through the DOH online application portal for Home Care Agencies.
• Administrator Qualifications: The agency administrator must be at least 18 years old, possess a high school diploma or GED, and complete state-mandated training.
• Fee: A $100 initial application fee is required for a Home Care Agency license.
• Survey: A pre-licensure inspection by DOH surveyors is mandatory to verify the physical office and policy compliance before the license is issued.

5. Medicaid Provider Enrollment

Once licensed by the DOH, the agency must enroll as a Medicaid provider through the Department of Human Services using the PROMISe portal. This system handles all provider enrollment, revalidation, and user management for Pennsylvania Medical Assistance.

PAS providers are subject to strict screening requirements under the Affordable Care Act. Because personal care is considered a high-risk category for fraud, waste, and abuse, owners are subject to fingerprinting and background checks during enrollment.

• System: PROMISe (Provider Reimbursement and Operations Management Information System).
• Provider Type: PAS agencies typically enroll under Provider Type 59 (In-Home Non-Nursing) depending on the specific CHC billing taxonomy.
• Application Fee: Subject to the federal Medicaid institutional provider application fee (approximately $709 for 2024/2025).
• Risk Category: Categorized as High risk, requiring fingerprint-based criminal background checks for all owners with a 5 percent or greater interest.
• Revalidation: Providers must revalidate their PROMISe enrollment every 5 years to maintain active status.

6. Staffing, Training and Background Checks

Pennsylvania enforces rigorous background check and training standards to protect vulnerable adults receiving home care. The Older Adults Protective Services Act (Act 169) dictates the criminal history requirements for all direct care workers.

Before providing unsupervised care, all PAS staff must complete a state-mandated training curriculum. Agencies must maintain meticulous personnel files to prove compliance during DOH surveys.

• Background Checks: Act 169 of 1996 requires Pennsylvania State Police criminal history checks for all employees with direct consumer contact.
• Child Abuse Clearance: Required if the agency serves any individuals under the age of 18.
• Initial Training: Direct care workers must complete a minimum of 40 hours of training before providing unsupervised care, per 28 PA Code Chapter 611.
• Competency: Workers must pass a competency evaluation covering ADLs, infection control, and emergency procedures.
• Health Screening: Staff must have a negative TB test documented prior to their first direct client contact.

7. Documentation, Policies and Records

Compliance in Pennsylvania requires maintaining extensive documentation for both consumers and employees. The DOH requires agencies to have a comprehensive policy manual that covers everything from hiring practices to emergency preparedness.

Additionally, Pennsylvania mandates the use of Electronic Visit Verification (EVV) for all personal care services. Providers must integrate their scheduling systems with the state's aggregator to ensure all shifts are electronically logged.

• Consumer Roster: Agencies must maintain an active, up-to-date roster of all consumers as required by DOH regulations.
• Service Plan: A written, individualized service plan must be developed for each consumer and updated annually or upon a significant change in condition.
• EVV Compliance: Providers must use the DHS-integrated Sandata EVV system or an approved alternate EVV vendor to record all PAS shifts.
• Personnel Records: Files must contain I-9s, Act 169 clearances, TB test results, and certificates proving the 40-hour training completion.
• Incident Reporting: Agencies must implement policies that align with the Enterprise Incident Management (EIM) system for reporting critical incidents.

8. Billing, Rates and Claims

In the Community HealthChoices program, PAS providers do not typically bill the state directly; instead, they submit claims to the specific MCO with which the consumer is enrolled. Rates are negotiated with the MCOs, though they are heavily influenced by the DHS Office of Long-Term Living fee schedule.

Accurate billing requires strict adherence to EVV mandates. Claims submitted to an MCO that do not have a corresponding, verified EVV record will be automatically denied.

• Billing System: Claims are submitted directly to the contracted CHC MCO (e.g., UPMC, AmeriHealth) rather than the state, except in rare fee-for-service cases.
• Procedure Code: PAS is typically billed using HCPCS code W1793 or T1019, depending on the specific waiver and MCO guidelines.
• Unit Measurement: Services are billed in 15-minute increments.
• Rate Structure: MCOs pay negotiated rates that generally benchmark against the DHS OLTL fee schedule, varying slightly by geographic region.
• EVV Linkage: Claims will be denied by the MCO if they are not matched to a verified Electronic Visit Verification record.

9. Approval Sequence and Timeline

Becoming a fully operational Medicaid PAS provider in Pennsylvania is a sequential process that cannot be rushed. An agency cannot apply for Medicaid until the DOH license is in hand, and cannot bill Medicaid until MCO contracts are signed.

The entire timeline from business formation to seeing the first Medicaid client typically takes 6 to 12 months, with MCO credentialing often being the longest and most unpredictable phase.

• Step 1: Register the business entity with the Pennsylvania Department of State (typically takes 1-2 weeks).
• Step 2: Submit the DOH Home Care Agency application and pass the pre-licensure survey (typically takes 60-90 days).
• Step 3: Submit the PROMISe Medicaid enrollment application and undergo high-risk screening (typically takes 45-90 days).
• Step 4: Apply for credentialing and contract negotiation with regional CHC MCOs (typically takes 90-120+ days, assuming networks are open).

10. Common Denials and Survey Findings

New providers frequently face delays or denials due to administrative oversights during the application and survey phases. DOH surveyors are particularly strict about personnel files and physical office requirements.

On the Medicaid side, PROMISe applications are often rejected for mismatched data, while MCO applications are frequently denied simply because the network has enough providers in a given county.

• Licensure Denial: Failure to have a fully equipped, commercial office space ready and accessible during the DOH pre-licensure survey.
• Personnel File Citations: Missing Act 169 background checks or TB tests dated prior to the employee's first day of patient contact.
• Training Deficiencies: Incomplete or missing documentation proving the mandated 40-hour direct care worker training was completed.
• PROMISe Rejection: Mismatched legal names or Tax IDs between the IRS documentation, DOH license, and PROMISe application.
• MCO Rejection: Denied network entry due to MCO network adequacy, meaning the plan is not accepting new PAS providers in that specific county.

11. Key Contacts and Resources

Navigating the Pennsylvania PAS landscape requires interacting with multiple state portals and managed care websites. Providers should bookmark these official resources for applications, regulations, and billing updates.

Because MCO networks manage the actual flow of clients, maintaining direct contact with the provider relations departments of the CHC plans is critical for business viability.

• PA DOH Home Care Division: https://www.health.pa.gov/topics/facilities/home-care/Pages/Home-Care.aspx
• PROMISe Provider Portal: https://provider.enrollment.dhs.pa.gov/
• PA DHS Office of Long-Term Living (OLTL): https://www.dhs.pa.gov/about/Pages/OLTL.aspx
• PA Health & Wellness (MCO): https://www.pahealthwellness.com/providers/become-a-provider.html
• UPMC Community HealthChoices (MCO): https://www.upmchealthplan.com/providers/chc/
• AmeriHealth Caritas PA (MCO): https://www.amerihealthcaritaspa.com/provider/index.aspx

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