Pennsylvania - Prevocational Services — Licensing, Medicaid Enrollment and Startup Requirements

Last reviewed: 2026-09-10

Pennsylvania’s Office of Developmental Programs (ODP) funds time-limited work readiness training through the Consolidated, Community Living, and Person/Family Directed Support (P/FDS) waivers, categorizing these supports under Community Participation Support (CPS) and facility-based Prevocational Services. Prospective agencies must secure an approved ODP Provider Qualification Form DP 1059 from their designated county Administrative Entity (AE) before the state will accept a Medicaid enrollment application.

The approval sequence mandates that the agency's Chief Executive Officer complete the ODP Provider Applicant Orientation and pass a rigorous New Provider Self-Assessment. Facilities operating physical day sites must also secure a Chapter 2380 or Chapter 2390 license from the Department of Human Services prior to rendering services.

1. Service Definition and Scope

In Pennsylvania, general work readiness training is delivered via Prevocational Services and Community Participation Support (CPS) under ODP waivers. These services focus on developing competitive worker traits, attendance, and task completion rather than job-specific skills.

The service is designed as a stepping stone to competitive integrated employment and is delivered either in licensed facilities or integrated community hubs.

• Target Population: Individuals enrolled in the Consolidated, Community Living, or P/FDS waivers (this service is explicitly excluded from the Adult Autism Waiver).
• Service Locations: Licensed Vocational Facilities, Adult Training Facilities, or integrated community settings.
• OVR Coordination: Participants under age 25 must generally be referred to the Office of Vocational Rehabilitation (OVR) before waiver-funded prevocational services are authorized.
• Time Limitations: Services are time-limited and focused on transitioning the participant to competitive integrated employment.

2. Regulatory and Oversight Agencies

The Pennsylvania Department of Human Services (DHS) manages the Medicaid program, with specific waiver operations delegated to the Office of Developmental Programs (ODP). County-level Administrative Entities (AEs) act as the local gatekeepers for provider qualification.

Facility licensure is handled separately by the DHS Bureau of Human Services Licensing.

• Operating Agency: Office of Developmental Programs (ODP) (https://www.dhs.pa.gov/about/DHS-Information/Pages/Office-of-Developmental-Programs.aspx)
• Licensing Authority: DHS Bureau of Human Services Licensing (BHSL) (https://www.dhs.pa.gov/providers/Clearances-and-Licensing/Pages/default.aspx)
• Local Oversight: County Administrative Entities (AEs) (https://www.dhs.pa.gov/providers/Providers/Pages/ODP-Administrative-Entities.aspx)
• Medicaid Agency: DHS Office of Medical Assistance Programs (OMAP) (https://www.dhs.pa.gov/about/DHS-Information/Pages/Office-of-Medical-Assistance-Programs.aspx)

3. Gatekeeping Prerequisites: Who Can Even Apply

Pennsylvania utilizes a strict county-level qualification gate before Medicaid enrollment. Providers cannot simply apply to the state; they must be vetted and approved by their local AE.

Additionally, the state imposes strict size and location caps on new facilities to comply with federal integration mandates.

• Mandatory Orientation: The agency CEO or Executive Director must successfully complete the ODP Provider Applicant Orientation before submitting any documentation.
• County AE Approval: Applicants must submit their qualification documentation to their Assigned AE and receive an approved ODP Provider Qualification Form DP 1059.
• New Provider Self-Assessment: Agencies must complete and pass the ODP New Provider Self-Assessment, submitting vetted policies and procedures to the AE.
• Facility Size Cap: Community Participation Support cannot be provided in a licensed facility enrolling after March 17, 2019, that serves more than 25 individuals at any one time.

4. Licensure and Certification Requirements

If the service is delivered in a provider-owned or operated facility, specific DHS licensure is required under Title 55 of the Pennsylvania Code. Community-only delivery models may bypass facility licensure but must still meet ODP qualification standards.

All new locations must pass an onsite inspection to verify compliance with the HCBS Settings Rule.

• Vocational Facilities: Licensure under 55 Pa. Code Chapter 2390 is required for facility-based prevocational services.
• Adult Training Facilities: Licensure under 55 Pa. Code Chapter 2380 is required for day habilitation/CPS settings.
• HCBS Settings Rule Inspection: Facilities must pass an onsite inspection by ODP staff ensuring the location is integrated and not adjacent to another human service residential or day facility.
• Waiver Provider Agreement: All providers must sign the ODP Waiver Provider Agreement binding them to state and federal regulations.

5. Medicaid Provider Enrollment

Once the DP 1059 is secured, providers apply through the state's Medicaid Management Information System. ODP staff then provision the provider in the Home and Community Services Information System (HCSIS).

Providers cannot bill for services until they are fully active in both PROMISe and HCSIS.

• Enrollment Portal: MA Program On-line Provider Enrollment Application System (PROMISe) (https://promise.dpw.state.pa.us)
• Required Upload: The approved Form DP 1059 must be uploaded with the electronic PROMISe application.
• System Access: ODP Provider Enrollment staff contact the HCSIS Help Desk to assign the provider an ODP role using their FEIN and unique email.
• Service Addition: Providers must log into HCSIS (https://www.hcsis.state.pa.us) to add the specific services for which they are qualified.

6. Staffing, Training and Background Checks

Direct support professionals delivering prevocational services must meet baseline ODP qualifications. Enhanced levels of service require specific staff credentials.

Agencies must maintain strict compliance with state clearance laws for all employees.

• Age Requirement: Direct service workers must be at least 18 years of age.
• Clearances: Staff must obtain Pennsylvania State Police criminal history clearances, and FBI fingerprint checks if they have not been PA residents for two consecutive years.
• Child Abuse Clearance: Required if the staff member will be serving participants under the age of 18.
• Training: Staff must complete ODP-mandated annual training, including incident management and HCBS settings requirements.
• Enhanced Service Qualifications: Enhanced reimbursement levels require staff to hold specific degrees or certifications, based on the participant's assessed need, not just the worker's credentials.

7. Documentation, Policies and Records

ODP requires extensive policy documentation during the Self-Assessment phase and ongoing record-keeping to justify service delivery and billing.

Providers must prove that services are not duplicative of other federally funded programs.

• IDEA Documentation: Files must contain documentation satisfying assurances that the service is not otherwise available through a program funded under the Individuals with Disabilities Education Act (IDEA).
• ISP Authorization: The specific service, provider, and location must be explicitly authorized in the participant’s Individual Support Plan (ISP).
• Record Retention: Providers must maintain all service notes, attendance logs, and billing records in accordance with ODP and MA standards.
• Quality Management Plan: Agencies must develop and implement an ODP-approved Quality Management Plan.

8. Billing, Rates and Claims

Reimbursement is processed through PROMISe based on fee-schedule rates established by ODP. Services are billed in discrete units, typically 15-minute increments.

Certain activities, such as travel time, are explicitly excluded from discrete billing.

• Billing System: Claims are submitted through the PROMISe portal.
• Non-Billable Time: Travel time may not be billed by the provider as a discrete unit of this service.
• Rate Tiers: Services may be provided at varying levels (e.g., facility vs. community hub), with enhanced rates available for participants with higher assessed needs.
• Exclusions: Handicapped employment as defined in Title 55, Chapter 2390 may not be funded through the Waiver.

9. Approval Sequence and Timeline

The timeline from initial orientation to billing readiness spans several months, heavily dependent on the county AE's review schedule and facility licensure timelines.

Providers must complete the steps in a strict sequential order.

• Step 1: CEO completes ODP Provider Applicant Orientation.
• Step 2: Submit New Provider Self-Assessment and policies to the Assigned AE.
• Step 3: AE issues approved Form DP 1059.
• Step 4: Submit PROMISe enrollment application with DP 1059.
• Step 5: Receive HCSIS access and add qualified services.

10. Common Denials and Survey Findings

Applications are frequently rejected at the AE level due to incomplete policy submissions or failure to meet HCBS Settings Rule criteria.

Licensure surveys often cite facilities for failing to maintain community integration standards.

• Settings Rule Violations: Proposing a facility location that is adjacent to another human service residential or day facility.
• Size Cap Violations: Attempting to enroll a new facility that serves more than 25 individuals.
• Missing DP 1059: Submitting a PROMISe application before obtaining the approved DP 1059 from the AE.
• Inadequate Policies: Failing the New Provider Self-Assessment due to generic policies that do not meet PA Chapter 6100 or waiver requirements.

11. Key Contacts and Resources

Providers must utilize official DHS and ODP portals for regulations, bulletins, and system access.

The ODP Listserv is the primary method for receiving policy updates and announcements.

• ODP Provider Qualification Information: (https://www.dhs.pa.gov/providers/Providers/Pages/ODP-Provider-Qualifications.aspx)
• PROMISe Enrollment Portal: (https://promise.dpw.state.pa.us)
• HCSIS Login: (https://www.hcsis.state.pa.us)
• DHS Bureau of Human Services Licensing: (https://www.dhs.pa.gov/providers/Clearances-and-Licensing/Pages/default.aspx)

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