Pennsylvania - Personal Assistance Services — Licensing, Medicaid Enrollment and Startup Requirements
Last reviewed: 2026-09-10
The Pennsylvania Department of Health (DOH) licenses Personal Assistance Services (PAS) providers as Home Care Agencies under 28 Pa. Code Chapter 611 to deliver non-medical hands-on assistance in a participant's home. Funding for these services is primarily administered by the Department of Human Services (DHS) Office of Long-Term Living (OLTL) through the Community HealthChoices (CHC) 1915(c) waiver.
Because Pennsylvania operates its primary adult HCBS program through a mandatory managed care model, obtaining a state license and enrolling in the PROMISe Medicaid portal only qualifies an agency to seek contracts with the three regional CHC Managed Care Organizations (MCOs). These MCOs control network access, authorize all PAS hours, and may close their networks to new providers if they determine adequate capacity exists in a given county.
1. Service Definition and Scope
In Pennsylvania, Personal Assistance Services (PAS) provide hands-on assistance with Activities of Daily Living (ADLs) such as bathing, dressing, transferring, and toileting, as well as Instrumental Activities of Daily Living (IADLs). These services are designed to allow individuals with physical disabilities or age-related frailties to remain in their own homes.
The state distinguishes PAS from Home Health services; PAS is strictly non-medical. Providers delivering PAS cannot provide skilled nursing or therapeutic services unless they hold a separate Home Health Agency license.
- Service Name: Personal Assistance Services (PAS)
- Licensure Category: Home Care Agency (HCA) or Home Care Registry (HCR)
- Scope of Practice: Non-skilled assistance with ADLs, IADLs, and general companionship
- Exclusions: Skilled nursing, wound care, and medical administration
- Primary Funding Authority: Community HealthChoices (CHC) Waiver
2. Regulatory and Oversight Agencies
The Pennsylvania Department of Health (DOH) is responsible for the licensure and ongoing regulatory surveying of Home Care Agencies. The Department of Human Services (DHS) oversees Medicaid enrollment and the waiver programs.
Within DHS, the Office of Long-Term Living (OLTL) manages the Community HealthChoices program, while the actual day-to-day administration and provider contracting are handled by the designated Managed Care Organizations (MCOs).
- Licensing Agency: Pennsylvania Department of Health (DOH) (https://www.health.pa.gov/topics/facilities/home-care/Pages/Home-Care.aspx)
- Medicaid Authority: Pennsylvania Department of Human Services (DHS) (https://www.dhs.pa.gov)
- Waiver Operating Agency: Office of Long-Term Living (OLTL) (https://www.dhs.pa.gov/about/DHS-Information/Pages/Office-of-Long-Term-Living.aspx)
- Medicaid Portal: PROMISe Provider Portal (https://promise.dhs.pa.gov/portal/provider/Home/tabid/135/Default.aspx)
- Managed Care Entities: UPMC Community HealthChoices, PA Health & Wellness, AmeriHealth Caritas (https://www.dhs.pa.gov/HealthChoices/HC-Services/Pages/CHC-Main.aspx)
3. Gatekeeping Prerequisites: Who Can Even Apply
Pennsylvania requires providers to navigate a multi-tiered approval process where state licensure is merely the first step. The most definitive structural precondition is the requirement to contract with a Community HealthChoices (CHC) Managed Care Organization (MCO).
Enrollment in the state's Medicaid program does not guarantee an MCO contract. MCOs utilize network adequacy standards and may enact closed networks or moratoria in specific counties, blocking new PAS providers from receiving authorizations regardless of their licensure status.
- Managed Care Contracting: Must secure a contract with at least one CHC MCO (UPMC, PA Health & Wellness, or AmeriHealth Caritas) to receive participant authorizations
- Network Adequacy Closures: MCOs may refuse to contract with new PAS providers if they determine sufficient network capacity already exists in the provider's target region
- Licensure Prerequisite: Must hold an active Home Care Agency license from DOH before a PROMISe Medicaid enrollment application will be approved
- Categorical Risk Level: PAS is designated as a "high" categorical risk by DHS, requiring FBI and PA State Police background checks for all owners with 5% or more interest prior to enrollment
4. Licensure and Certification Requirements
To operate as a PAS provider, an entity must obtain a Home Care Agency license from the DOH Division of Home Health. The application process requires submission of specific state forms and a non-refundable fee.
The DOH mandates that all applications be typed and mailed physically; handwritten applications are rejected. The state currently advises that processing times for initial applications are extended.
- Regulation Citation: 28 Pa. Code Chapter 611
- Application Fee: $100 check or money order made payable to "Commonwealth of PA"
- Submission Method: Typed and mailed to Division of Home Health, 2525 N. 7th Street, Harrisburg, PA 17110
- Required Forms: Identifying Information, Password Agreement, Civil Rights Survey, and Home Care Agency Licensure Survey
- Processing Timeframe: DOH currently estimates 2-3 months or longer for initial home care agency applications
5. Medicaid Provider Enrollment
Once licensed, providers must enroll in Pennsylvania Medicaid through the PROMISe Provider Portal. This step establishes the provider's Medicaid ID, which is required before approaching MCOs for contracting.
During enrollment, the system generates an Application Tracking Number (ATN) used to resume or check the status of the application. High-risk screening requirements apply to all PAS applicants.
- System Name: PROMISe Provider Portal
- Tracking Identifier: Application Tracking Number (ATN) assigned upon starting a new application
- Application Fee: Subject to the federal Medicaid institutional provider application fee unless waived or paid to Medicare
- Background Checks: FBI and PA State Police Criminal Record Checks required for all individuals with 5% or greater ownership
- Revalidation: Providers must complete an Electronic Revalidation Application through PROMISe every 5 years
6. Staffing, Training and Background Checks
Direct care workers providing PAS must meet specific screening and training standards outlined in 28 Pa. Code Chapter 611. Agencies are responsible for maintaining documentation of these requirements in personnel files.
Before independent client contact, workers must demonstrate competency and pass health and background screenings to ensure consumer safety.
- Criminal Background Checks: Pennsylvania State Police criminal record check required for all direct care workers prior to hire
- Child Abuse Clearance: Required if the agency serves individuals under 18 years of age
- Health Screening: Tuberculosis (TB) testing required prior to direct consumer contact
- Competency Standard: Workers must pass a competency exam or complete a state-approved training program per 28 Pa. Code § 611.55
- Consumer Notice: Agencies must provide consumers with the Consumer Notice of Direct Care Worker Status form
7. Documentation, Policies and Records
Home Care Agencies must maintain comprehensive records for both consumers and staff. DOH surveyors will review these records during initial and renewal inspections.
Additionally, Pennsylvania mandates the use of Electronic Visit Verification (EVV) for all personal care services to comply with the 21st Century Cures Act.
- Consumer Records: Must include service plans, dates and times of service, and direct care worker notes
- Roster Requirement: Agencies must maintain a current roster of all direct care workers and active consumers
- EVV Mandate: Electronic Visit Verification is mandatory for all PAS visits using the state's Sandata system or a certified alternate system
- Record Retention: Medicaid regulations require records to be retained for a minimum of 4 years
8. Billing, Rates and Claims
Because PAS under the CHC waiver is managed by MCOs, providers do not bill the state directly through PROMISe for these services. Instead, claims are submitted to the specific MCO's clearinghouse.
Reimbursement rates are negotiated directly between the provider and the MCO, though the state publishes a Medical Assistance fee schedule that often serves as a baseline.
- Billing System: Claims are submitted to the respective CHC MCO, not directly to the state PROMISe system
- Reimbursement Rates: Negotiated with MCOs; baseline rates are published in the PA Medical Assistance fee schedule
- EVV Integration: Claims will be denied by the MCO if they are not matched with a valid, compliant EVV record
- Procedure Codes: Typically billed under W1793 or T1019, depending on the specific MCO fee schedule and modifier requirements
9. Approval Sequence and Timeline
Becoming a fully operational PAS provider in Pennsylvania is a sequential process that can take 6 to 12 months from start to finish, heavily dependent on MCO contracting timelines.
Providers cannot skip steps; licensure must precede Medicaid enrollment, which must precede MCO contracting.
- Step 1: Register the business entity and obtain a Federal Tax ID (EIN)
- Step 2: Submit the typed Home Care Agency application to DOH (takes 2-3 months)
- Step 3: Apply for Medicaid enrollment via the PROMISe portal (takes 30-60 days)
- Step 4: Apply for network inclusion with the regional CHC MCOs (timeline varies, often 90+ days)
- Step 5: Complete EVV system training and integration prior to billing
10. Common Denials and Survey Findings
Applications are frequently delayed or denied due to administrative errors or failure to meet the high-risk background check requirements. DOH is strict about application formatting.
During operational surveys, DOH frequently cites agencies for incomplete personnel files, particularly missing health screenings or competency documentation.
- Formatting Errors: Submitting handwritten applications to DOH instead of the required typed format
- Background Check Gaps: Failing to obtain FBI background checks for 5% owners under the PROMISe high-risk screening rules
- MCO Network Closure: Receiving denials for MCO contracts because the MCO determines there is no network need in the requested counties
- Personnel File Deficiencies: Missing TB tests, background checks, or competency exams in direct care worker files during DOH surveys
11. Key Contacts and Resources
Providers should rely on official Commonwealth of Pennsylvania websites for the most current forms, fee schedules, and regulatory updates.
The PROMISe portal and DOH Home Care pages are the primary hubs for enrollment and licensure activities.
- PA Department of Health (Home Care): https://www.health.pa.gov/topics/facilities/home-care/Pages/Home-Care.aspx
- PROMISe Provider Portal: https://promise.dhs.pa.gov/portal/provider/Home/tabid/135/Default.aspx
- DHS Provider Enrollment Information: https://www.pa.gov/services/dhs/enroll-as-a-medicaid-provider
- Community HealthChoices (CHC) Information: https://www.dhs.pa.gov/HealthChoices/HC-Services/Pages/CHC-Main.aspx
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