Pennsylvania - Skilled Respite Service — Licensing, Medicaid Enrollment and Startup Requirements
Last reviewed: 2026-09-10
The Pennsylvania Department of Human Services (DHS) funds Skilled Respite through the Office of Developmental Programs (ODP) Consolidated, Community Living, and Person/Family Directed Support (P/FDS) waivers, as well as the Office of Long-Term Living (OLTL) Community HealthChoices (CHC) program. The service provides temporary relief to primary caregivers by utilizing licensed nursing staff (RNs or LPNs) to support participants with complex medical needs that exceed the scope of standard, unlicensed respite care.
Before a provider can bill for this service, they must pass the ODP New Provider Qualification process administered by a regional Administrative Entity (AE) or secure a network contract with a CHC Managed Care Organization (MCO). Pennsylvania does not issue a distinct facility license for "Skilled Respite"; instead, agencies typically operate under a Department of Health (DOH) Home Care Agency or Home Health Agency license and enroll their nursing staff through the PROMISe Medicaid portal.
1. Service Definition and Scope
In Pennsylvania, Skilled Respite is defined as short-term nursing support provided to individuals whose medical conditions require the clinical expertise of a Registered Nurse (RN) or Licensed Practical Nurse (LPN). It is designed to relieve the primary unpaid caregiver while ensuring the participant's health and safety needs are met.
The service can be delivered in the participant's home, a licensed respite facility, or a community setting, depending on the specific waiver authorization. It is strictly limited to tasks that fall under the state's Nurse Practice Act and cannot be used for routine companion care.
- Service Name: Skilled Respite
- Funding Authority: ODP Waivers (Consolidated, Community Living, P/FDS) and OLTL Community HealthChoices
- Delivery Settings: Participant's private home, unlicensed community settings, or licensed facilities
- Clinical Scope: Medication administration, tube feeding, tracheostomy care, and other skilled nursing tasks
- Exclusions: Cannot be billed concurrently with standard unlicensed respite or continuous shift nursing
2. Regulatory and Oversight Agencies
Multiple state agencies oversee the delivery of Skilled Respite in Pennsylvania. The Department of Human Services (DHS) manages the Medicaid waivers, while specific program offices handle day-to-day policy and provider qualification.
The Department of Health (DOH) is responsible for the underlying licensure of the agencies employing the nurses, ensuring compliance with state health and safety regulations.
- Primary Agency: Pennsylvania Department of Human Services (DHS) (https://www.dhs.pa.gov)
- ODP Oversight: Office of Developmental Programs (https://www.dhs.pa.gov/about/Pages/ODP.aspx)
- OLTL Oversight: Office of Long-Term Living (https://www.dhs.pa.gov/about/Pages/OLTL.aspx)
- Licensing Body: Pennsylvania Department of Health (DOH) (https://www.health.pa.gov)
- Medicaid Portal: PROMISe Provider Portal (https://promise.dhs.pa.gov)
3. Gatekeeping Prerequisites: Who Can Even Apply
Pennsylvania requires providers to clear specific structural hurdles before an enrollment application is accepted. For ODP waivers, providers must undergo the New Provider Qualification process, which requires sponsorship and review by a county-level Administrative Entity (AE).
For the OLTL Community HealthChoices program, providers face a closed-network managed care environment. Enrollment in the state Medicaid system does not guarantee the ability to bill; providers must successfully negotiate and execute a contract with one of the regional MCOs.
- ODP Prerequisite: Successful completion of the ODP New Provider Qualification process via a regional Administrative Entity (AE)
- OLTL Prerequisite: Executed network contract with a Community HealthChoices MCO (e.g., UPMC, PA Health & Wellness, AmeriHealth Caritas)
- Licensure Prerequisite: Active Home Care Agency or Home Health Agency license from the PA Department of Health
- Business Registration: Registration with the PA Department of State and acquisition of a Federal Employer Identification Number (FEIN)
- Need Review: MCOs may deny contracting based on network adequacy (closed networks)
4. Licensure and Certification Requirements
Because Pennsylvania does not have a specific "Skilled Respite" license category, agencies must hold an appropriate overarching license to deploy nursing staff. Most commonly, this is a Home Care Agency license or a Home Health Agency license issued by the DOH.
Agencies must comply with 55 Pa. Code Chapter 6100 regulations for ODP services, which dictate administrative, training, and incident management standards.
- Agency License: PA DOH Home Care Agency or Home Health Agency license
- ODP Regulation: Compliance with 55 Pa. Code Chapter 6100 (Services for Individuals with an Intellectual Disability or Autism)
- Nursing Licenses: Active, unencumbered PA RN or LPN licenses for all direct care staff
- Program Administrator: Must meet experience and education thresholds outlined in 55 Pa. Code § 6100.57
- CPR Certification: All nursing staff must hold current CPR and First Aid certifications
5. Medicaid Provider Enrollment
Once qualified by ODP or contracted with an MCO, providers must enroll in the Pennsylvania Medicaid program through the PROMISe portal. This process assigns a 13-digit Master Provider Index (MPI) number.
Providers must submit an electronic application, pay the required application fee (if applicable), and undergo categorical risk screening.
- Enrollment Portal: PROMISe Provider Portal (https://promise.dhs.pa.gov)
- Provider Type: Typically Provider Type 59 (Home and Community Based Services) or 38 (Home Health)
- Application Fee: Subject to the federal Medicaid/Medicare institutional provider application fee (varies annually, approx. $700)
- Risk Level: Often categorized as "high" risk, requiring fingerprint-based background checks for owners with 5% or more interest
- Revalidation: Required every 5 years through the PROMISe portal
6. Staffing, Training and Background Checks
Staffing for Skilled Respite is strictly limited to Pennsylvania-licensed RNs and LPNs. Unlicensed direct support professionals (DSPs) cannot deliver this specific service tier.
All staff and individuals with significant ownership interest must pass rigorous background checks, including FBI fingerprinting, due to the high-risk classification of the service.
- Clinical Staff: Must hold an active PA RN or LPN license
- State Background Check: Pennsylvania State Police Criminal Record Check required for all staff
- Federal Background Check: FBI fingerprint-based background check required for staff and owners (MA Bulletin 99-17-03)
- Child Abuse Clearance: PA Child Abuse History Clearance required if serving individuals under 18
- Annual Training: Minimum of 24 hours of annual training required for ODP providers per Chapter 6100
7. Documentation, Policies and Records
Providers must maintain comprehensive clinical and administrative records. For Skilled Respite, this includes detailed nursing notes that justify the medical necessity of the skilled intervention during the respite period.
Agencies must also have approved policies for incident management, quality management, and grievance procedures as dictated by ODP and DOH regulations.
- Service Notes: Must include date, start/stop times, specific skilled tasks performed, and nurse signature
- Care Plan: Services must align exactly with the participant's Individual Support Plan (ISP) or Person-Centered Service Plan (PCSP)
- Incident Management: Mandatory use of the Enterprise Incident Management (EIM) system for reporting critical incidents
- Record Retention: Records must be kept for a minimum of 5 years, or longer if under audit
- Quality Management: Must maintain an active Quality Management Plan updated every 2 years
8. Billing, Rates and Claims
Billing for Skilled Respite is processed through the PROMISe system for fee-for-service ODP waivers, or through the respective MCO's clearinghouse for CHC participants. Rates are established by DHS and vary based on whether an RN or LPN provides the service.
Services are typically billed in 15-minute units. Providers must ensure they do not exceed the authorized units on the participant's service plan.
- Billing System (ODP): PROMISe portal using standard 837P electronic claims
- Billing System (CHC): Submitted directly to the contracted MCO's designated clearinghouse
- Unit of Service: Typically billed in 15-minute increments
- Rate Setting: ODP publishes fee schedule rates annually via the PA Bulletin
- Prior Authorization: 100% of skilled respite units must be prior-authorized on the ISP/PCSP before delivery
9. Approval Sequence and Timeline
The timeline to become a fully approved Skilled Respite provider in Pennsylvania can take 6 to 12 months. The process is sequential and cannot be expedited.
Providers must first secure their DOH license, then pass ODP qualification or secure MCO contracts, and finally complete the PROMISe enrollment.
- Step 1: Obtain PA DOH Home Care or Home Health Agency license (3-6 months)
- Step 2: Complete ODP New Provider Qualification via local AE (2-4 months)
- Step 3: Submit PROMISe Medicaid Enrollment application (1-3 months)
- Step 4: MCO Contracting (for CHC): Negotiate and execute contracts (3-6 months, often concurrent with PROMISe)
- Step 5: Receive Master Provider Index (MPI) number and begin accepting authorizations
10. Common Denials and Survey Findings
Applications are frequently delayed or denied due to incomplete background checks or failure to meet the strict Program Administrator qualifications under Chapter 6100.
During audits, the most common citations involve billing for skilled respite when the documentation only supports standard, non-skilled companion care.
- Application Denial: Failure to submit FBI fingerprint checks for all 5% or greater owners
- Qualification Denial: Program Administrator lacks the required degree or years of developmental disability experience
- Audit Finding: Nursing notes lack clinical detail, resembling standard DSP daily logs
- Audit Finding: Billing for overlapping times (e.g., billing respite while the participant is at a day program)
- Survey Citation: Failure to report incidents into the EIM system within the mandatory 24-hour window
11. Key Contacts and Resources
Prospective providers should utilize the official DHS portals and regional Administrative Entities for guidance. The PROMISe portal contains all necessary enrollment forms and manuals.
For MCO contracting, providers must reach out directly to the provider relations departments of the active CHC plans in their specific geographic zone.
- PROMISe Enrollment Portal: https://promise.dhs.pa.gov
- ODP Provider Qualification: https://www.myodp.org
- PA Department of Health Licensure: https://www.health.pa.gov
- DHS Provider Enrollment Helpline: 1-800-537-8862
- Community HealthChoices Info: https://www.dhs.pa.gov/HealthChoices/HC-Services/Pages/CHC-Main.aspx
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