Pennsylvania - Skilled Respite Service — Licensing, Medicaid Enrollment and Startup Requirements
Last reviewed: 2026-08-16
In Pennsylvania, Skilled Respite Service is not licensed as a standalone category. Instead, it is delivered under the state's Medicaid Home and Community-Based Services (HCBS) waivers by agencies holding a Pennsylvania Department of Health (DOH) Home Care Agency or Home Health Agency license. This service provides temporary relief to primary caregivers of participants with complex medical needs, utilizing licensed nursing staff (RNs or LPNs) when the participant's care requirements exceed the scope of an unlicensed direct support professional.
The single biggest structural barrier to entry in Pennsylvania depends on the target waiver population. For aging and physical disability waivers under the Office of Long-Term Living (OLTL), the barrier is Managed Care Organization (MCO) network contracting; the state operates under the Community HealthChoices (CHC) managed care model, and MCOs frequently close their networks to new providers. For intellectual and developmental disability waivers under the Office of Developmental Programs (ODP), the primary barrier is the County Administrative Entity (AE) Provider Qualification (PQ) process, which acts as a strict gatekeeper that must approve your agency before you can even submit a Medicaid enrollment application.
1. Service Definition and Scope
Skilled Respite in Pennsylvania provides short-term, temporary relief to unpaid primary caregivers of individuals enrolled in Medicaid HCBS waivers. Because the participant requires continuous or complex medical interventions (such as ventilator management, tracheostomy care, or complex medication administration), the service must be delivered by licensed nursing personnel.
The service is authorized through the participant's Individual Support Plan (ISP) or Person-Centered Service Plan (PCSP). It can be delivered in the participant's home or in a licensed out-of-home setting, but it cannot be billed simultaneously with other direct care services like Community Participation Support or standard Residential Habilitation.
- Service Name: Respite (Skilled / Nursing level)
- Target Population: Individuals with intellectual/developmental disabilities (ODP waivers) or aging/physical disabilities (OLTL CHC waiver) requiring clinical care.
- Setting: In-home (most common) or licensed out-of-home facilities.
- Duration Limits (ODP): Typically limited to 480 15-minute units (120 hours) or up to 30 days per state fiscal year, depending on the specific waiver.
- Exclusions: Cannot be provided by the participant's legal guardian or legally responsible relative.
2. Regulatory and Oversight Agencies
Medicaid in Pennsylvania is administered by the Department of Human Services (DHS). Within DHS, two distinct program offices manage the waivers that fund Skilled Respite: the Office of Developmental Programs (ODP) for intellectual/developmental disabilities, and the Office of Long-Term Living (OLTL) for aging and physical disabilities.
Because Pennsylvania does not have a specific "Respite License," the physical licensure of the agency providing the nurses falls under the jurisdiction of the Pennsylvania Department of Health (DOH). Local oversight and initial provider qualification for ODP waivers are handled by county-level Administrative Entities (AEs).
- Primary Agency: Pennsylvania Department of Human Services (DHS)
- Waiver Administration (ID/A): DHS Office of Developmental Programs (ODP)
- Waiver Administration (Aging/Physical): DHS Office of Long-Term Living (OLTL)
- Licensing Authority: Pennsylvania Department of Health (DOH)
- Local Oversight (ODP): County Administrative Entities (AEs) or County MH/ID programs
3. Gatekeeping Prerequisites: Who Can Even Apply
Pennsylvania does not require a Certificate of Need (CON) for home care or respite agencies. However, the state imposes strict structural barriers that block applicants from enrolling in Medicaid depending on the waiver system they intend to serve.
For OLTL's Community HealthChoices (CHC), the absolute barrier is MCO network contracting; if the MCOs have closed networks due to regional adequacy, you cannot receive referrals or payment. For ODP, the barrier is the County Administrative Entity (AE) Provider Qualification (PQ) process, which must be passed in the Home and Community Services Information System (HCSIS) before a PROMISe Medicaid enrollment application is even permitted.
- Licensure Prerequisite: An active PA DOH Home Care Agency or Home Health Agency license is required before Medicaid enrollment can begin.
- ODP Gatekeeper: County Administrative Entity (AE) Provider Qualification (PQ) approval via HCSIS.
- OLTL Gatekeeper: Network contract execution with CHC MCOs (UPMC, PA Health & Wellness, or AmeriHealth Caritas).
- Network Status: MCOs may declare "closed networks" (moratoria) for new respite providers based on regional network adequacy.
- Certificate of Need: None required in Pennsylvania for this service category.
4. Licensure and Certification Requirements
To provide Skilled Respite in a participant's home, the agency must be licensed by the Pennsylvania Department of Health (DOH) as a Home Care Agency or a Home Health Agency. This licensure ensures the agency meets state standards for hiring, supervising, and deploying clinical staff.
The application process is managed through the DOH Enterprise Provider Registry (EPR) / State Agency Information System (SAIS). Providers must submit policies, ownership disclosures, and an application fee, followed by a state survey.
- License Type: Home Care Agency (or Home Health Agency)
- Regulatory Citation: 28 Pa. Code Chapter 611 (Home Care Agencies and Home Care Registries)
- Application Fee: $100 initial fee for a Home Care Agency license
- Application Portal: DOH Enterprise Provider Registry (EPR)
- Renewal: Annual renewal required with updated documentation and fees
5. Medicaid Provider Enrollment
Once licensed by DOH and qualified by the AE (for ODP) or contracted with an MCO (for OLTL), the agency must enroll in Pennsylvania's Medicaid Management Information System, known as PROMISe. Enrollment is conducted entirely online.
Providers use the DHS Provider Electronic Enrollment Portal (PEEP) to submit their application. The agency must enroll under the specific Provider Type and Specialty codes that correspond to the waivers they are authorized to bill.
- System: PROMISe (Provider Reimbursement and Operations Management Information System)
- Portal: DHS Provider Electronic Enrollment Portal (PEEP)
- Provider Type: Provider Type 59 (Home and Community Based Services) or Provider Type 38 (Home Health)
- NPI Requirement: Type 2 (Organizational) National Provider Identifier required
- Application Fee: Subject to the federal ACA institutional provider application fee (approx. $709 for 2024) unless waived by Medicare enrollment
6. Staffing, Training and Background Checks
Because this is a skilled service, direct care must be provided by nurses licensed by the Pennsylvania State Board of Nursing. The agency must also appoint administrative leadership that meets state regulatory standards.
Pennsylvania enforces strict background check requirements under the Child Protective Services Law (CPSL) and Older Adults Protective Services Act (OAPSA). All clearances must be obtained prior to the staff member's first day of patient contact.
- Clinical Staff: Active PA Registered Nurse (RN) or Licensed Practical Nurse (LPN) license.
- Administrator (ODP): Program Administrator must meet 55 Pa. Code § 6100.57 requirements (typically a bachelor's degree plus relevant experience).
- State Police Check: PATCH (Pennsylvania Access To Criminal History) required for all staff.
- Child Abuse Clearance: PA ChildLine clearance required.
- FBI Clearance: DHS-approved FBI fingerprint background check required.
- Training: ODP mandated reporter, Chapter 6100 orientation, and annual person-centered care modules.
7. Documentation, Policies and Records
Providers must maintain a comprehensive Policy & Procedure Manual that aligns with DOH Chapter 611 and DHS Chapter 6100 regulations. Documentation must prove that the skilled services delivered match the exact frequency and duration authorized in the ISP.
Incident management is highly scrutinized in Pennsylvania. Providers must use the state's Enterprise Incident Management (EIM) system to report critical incidents within strict timeframes.
- Care Plan: Individual Support Plan (ISP) for ODP or Person-Centered Service Plan (PCSP) for OLTL.
- Service Notes: Shift reports, daily logs, and Medication Administration Records (MAR).
- Incident Management: Critical incidents must be reported in the EIM system within 24 hours.
- Quality Management: Annual Quality Management Plan required per 55 Pa. Code § 6100.45.
- Record Retention: Minimum of 5 years per DHS regulations, or longer if under audit.
8. Billing, Rates and Claims
Billing procedures depend on the waiver. ODP claims are billed directly to PROMISe based on authorizations generated in HCSIS. OLTL CHC claims are billed to the specific MCO's clearinghouse (e.g., Change Healthcare, Availity).
Pennsylvania requires Electronic Visit Verification (EVV) for all in-home personal care and home health services, which includes in-home respite. Providers must use the DHS Sandata system or an approved alternate EVV vendor.
- Billing System (ODP): PROMISe via HCSIS service authorizations.
- Billing System (OLTL): MCO-specific clearinghouses.
- Procedure Codes: T1005 (Respite care services) with modifiers for nursing level (e.g., TD for RN, TE for LPN).
- Rate Structure (ODP): Fixed fee schedule published annually in the Pennsylvania Bulletin.
- EVV Requirement: Electronic Visit Verification required via DHS Sandata or certified alternate EVV.
9. Approval Sequence and Timeline
Becoming a Skilled Respite provider in Pennsylvania is a sequential process that typically takes 6 to 9 months from business formation to billing the first claim. Steps cannot be taken out of order, as each subsequent agency requires the approval of the previous one.
The longest delays usually occur during the DOH licensure phase and the MCO contracting phase, both of which are subject to state and corporate backlogs.
- Step 1: Business registration, EIN, and Type 2 NPI (1-2 weeks).
- Step 2: DOH Home Care Agency Licensure application and survey (90-120 days).
- Step 3: ODP Provider Qualification via AE / HCSIS (30-60 days).
- Step 4: PROMISe Enrollment via PEEP (30-60 days).
- Step 5: MCO Contracting for CHC (90-180 days, concurrent or post-PROMISe).
10. Common Denials and Survey Findings
Both DOH and DHS conduct routine and unannounced surveys. Initial applications are frequently delayed due to incomplete policy manuals or failure to properly map policies to the specific Pennsylvania Code citations.
Post-enrollment, the most common audit findings result in payment retractions. These usually stem from EVV non-compliance or gaps in mandatory staff background checks.
- Background Checks: Failure to obtain PATCH/ChildLine clearances before the first day of patient contact.
- Documentation: Service notes lacking exact start/stop times or failing to match EVV data.
- Training: Missing ODP-mandated annual training certificates in personnel files.
- Policies: Incomplete incident management or grievance policies submitted during DOH licensure.
- MCO Rejection: Denied network access due to MCO network adequacy (closed network).
11. Key Contacts and Resources
Navigating Pennsylvania's dual-waiver system requires utilizing specific state portals and help desks. Providers should bookmark the DHS and DOH resource pages for the most current regulatory bulletins.
The PROMISe Provider Service center and the DOH Resource Accounts are the primary points of contact for technical assistance during the enrollment and licensure phases.
- DHS Provider Enrollment: 1-800-537-8862 (PROMISe Provider Service)
- DOH Home Care Licensure: RA-DHHCA@pa.gov
- ODP Provider Qualification: Contact the local County Administrative Entity (AE) MH/ID office
- Portal: HCSIS (Home and Community Services Information System)
- Portal: PEEP (Provider Electronic Enrollment Portal)
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