Rhode Island - Integrated Employment — Licensing, Medicaid Enrollment and Startup Requirements

Last reviewed: 2026-09-10

The Rhode Island Department of Behavioral Healthcare, Developmental Disabilities and Hospitals (BHDDH) authorizes Integrated Employment services exclusively through the Developmental Disability Organization (DDO) licensure process under the state's Section 1115 Comprehensive Demonstration Waiver. Driven by a 2014 Department of Justice Consent Decree and the state's Employment First policy, Rhode Island requires providers to facilitate competitive work in community settings at or above minimum wage, utilizing specific variance forms if an individual chooses a non-integrated setting.

To bill Medicaid for this service, an agency cannot apply for a standalone employment certification; it must first submit the comprehensive DDO application to the BHDDH Office of Licensure and Standards and explicitly check the "Employment Services" certification box. Once licensed as a DDO, the agency must complete institutional provider enrollment through the Rhode Island Executive Office of Health and Human Services (EOHHS) via the RI Medicaid Healthcare Provider Portal to receive a Medicaid provider number and submit claims.

1. Service Definition and Scope

In Rhode Island, Integrated Employment (often categorized under Supported Employment) provides individualized assistance to help participants with developmental disabilities obtain and maintain competitive employment in integrated community settings. The service guarantees that individuals earn at least the prevailing minimum wage while working alongside people without disabilities.

The scope includes job development, placement, on-site job coaching, and ongoing retention supports. Rhode Island's Employment First policy dictates that community-based, integrated employment is the first and preferred service option, meaning providers must focus on competitive outcomes rather than sheltered workshops.

• Target Population: Adults with intellectual and developmental disabilities (I/DD) receiving services through BHDDH.
• Core Components: Job discovery, resume building, interview preparation, job matching, and on-site coaching.
• Wage Requirement: Participants must be compensated at or above the Rhode Island minimum wage, commensurate with customary rates paid by the employer for similar work.
• Setting Requirement: Work must occur in a competitive, integrated community environment, not a segregated facility.
• Variance Process: Individuals choosing not to work in integrated settings must have a completed "Variance to Work in a Segregated Employment Setting" form on file.
• Excluded Activities: Medicaid funds cannot be used to pay the participant's wages or to subsidize the employer.

2. Regulatory and Oversight Agencies

Oversight of Integrated Employment is bifurcated between the agency that manages the I/DD population and the single state Medicaid agency. BHDDH establishes the programmatic rules, issues the base license, and monitors compliance with the DOJ Consent Decree.

EOHHS serves as the financial and enrollment authority, managing the Medicaid state plan and the 1115 waiver. Gainwell Technologies operates the state's Medicaid Management Information System (MMIS) and provider portal on behalf of EOHHS.

• BHDDH Division of Developmental Disabilities: Manages participant eligibility and funding allocations (https://bhddh.ri.gov/developmental-disabilities).
• BHDDH Office of Licensure and Standards: Processes the DDO application and issues the physical license (https://bhddh.ri.gov/developmental-disabilities/providers/licensure-and-standards).
• RI Executive Office of Health and Human Services (EOHHS): The single state Medicaid agency governing reimbursement rules (https://eohhs.ri.gov/).
• RI Medicaid Healthcare Provider Portal: The Gainwell-operated system for Medicaid enrollment and claims submission (https://www.riproviderportal.org).

3. Gatekeeping Prerequisites: Who Can Even Apply

Rhode Island does not offer a standalone "Integrated Employment Provider" license. The absolute structural prerequisite is that an entity must apply for and obtain licensure as a Developmental Disability Organization (DDO) through BHDDH.

Furthermore, the state requires applicants to have a physical business location within Rhode Island that is publicly accessible and complies with the Americans with Disabilities Act (ADA). Out-of-state providers cannot enroll to provide this specific HCBS service without establishing a licensed in-state footprint.

• DDO Licensure Prerequisite: Applicants must meet all comprehensive organizational standards to become a licensed DDO before offering employment services.
• Physical Location Requirement: The agency must maintain a physical, ADA-compliant office location within the State of Rhode Island.
• FEIN Registration: The agency's Federal Employer Identification Number must be registered with the Rhode Island Division of Taxation.
• DOJ Consent Decree Compliance: Agencies must structurally align their business models with the state's Employment First mandate, eliminating sub-minimum wage models.

4. Licensure and Certification Requirements

To obtain the necessary credential, providers must submit the "DDO Application" to the BHDDH Office of Licensure and Standards. During this process, the applicant must specifically check the box for "Employment Services" under the requested certifications section.

The application requires extensive documentation, including organizational charts, financial viability proof, and comprehensive policy manuals. BHDDH conducts a thorough desk review and an on-site inspection before issuing the DDO license.

• Application Form: Submission of the official BHDDH DDO Application (updated 8-2021 or current version).
• Service Selection: Explicitly checking "Employment Services" on the DDO application checklist.
• Policy Submission: Providing written policies on participant rights, incident reporting, and Employment First principles.
• Fire Safety: Submission of current fire safety inspection certificates for the agency's physical location.
• Financial Documentation: Proof of financial stability and adequate insurance coverage (general and professional liability).
• Renewal Cycle: DDO licenses are typically issued for a two-year period and require periodic recertification by BHDDH.

5. Medicaid Provider Enrollment

Once the DDO license is secured, the agency must enroll as a billing provider with Rhode Island Medicaid. This is executed entirely online through the RI Medicaid Healthcare Provider Portal.

Providers must enroll under the specific HCBS waiver provider type and link their National Provider Identifier (NPI) to their BHDDH license. EOHHS requires an application fee for institutional providers, which covers federal screening mandates.

• Portal Registration: Completion of the enrollment application via https://www.riproviderportal.org.
• Provider Type: Selection of the appropriate HCBS Waiver provider type and specialty code for Supported Employment.
• Application Fee: Payment of the federally mandated Medicaid institutional provider application fee (unless waived via Medicare enrollment).
• NPI Requirement: Submission of a valid Type 2 (Organizational) National Provider Identifier.
• License Verification: Uploading the active BHDDH DDO license showing the Employment Services certification.
• EFT Enrollment: Mandatory setup of Electronic Funds Transfer for Medicaid claims payment.

6. Staffing, Training and Background Checks

Direct support professionals acting as job coaches or employment specialists must meet stringent training requirements to ensure they can effectively negotiate with employers and support participants. Rhode Island emphasizes national certification models for employment staff.

All staff must clear comprehensive state and federal background checks before having unsupervised contact with participants. Agencies are responsible for maintaining these training and background check records in personnel files.

• Background Checks: Mandatory Rhode Island Attorney General (BCI) check and fingerprint-based national criminal background check.
• Employment Certification: Staff are typically required to complete ACRE (Association of Community Rehabilitation Educators) basic training or hold a CESP (Certified Employment Support Professional) credential.
• First Aid/CPR: All direct care staff must hold current certification in basic First Aid and CPR.
• Abuse and Neglect Training: Mandatory training on identifying and reporting abuse, neglect, and exploitation to BHDDH.
• OIG Exclusion Check: Agencies must screen all staff against the federal LEIE and state Medicaid exclusion lists monthly.

7. Documentation, Policies and Records

Medicaid program integrity rules require meticulous documentation of every employment service rendered. The foundation of this documentation is the participant's Person-Centered Plan, which must explicitly authorize Integrated Employment.

Providers must track participant wages, hours worked, and the specific coaching interventions provided. BHDDH also requires the use of specific state forms to track employment outcomes and informed choice.

• Person-Centered Plan: The service must be documented and authorized in the individual's BHDDH-approved plan of care.
• Earnings Reporting: Providers must assist participants in completing the BHDDH Employment and Earnings Reporting Form.
• Progress Notes: Daily or per-session notes detailing the start/end times, specific coaching activities, and progress toward employment goals.
• Variance Forms: Maintenance of the "Variance to Work in a Segregated Employment Setting" form if the participant opts out of competitive integrated work.
• Record Retention: All Medicaid billing and clinical records must be retained for a minimum of ten years per EOHHS policy.

8. Billing, Rates and Claims

Integrated Employment claims are submitted electronically to the MMIS via the RI Medicaid Healthcare Provider Portal using standard HIPAA-compliant 837P formats. Services are typically billed in 15-minute increments using specific HCPCS codes and modifiers designated by EOHHS.

Because this service occurs in community workplaces rather than the participant's home, it is generally exempt from Electronic Visit Verification (EVV) requirements, though providers must still maintain strict timekeeping records.

• Claim Format: Electronic submission via the RI Provider Portal or clearinghouse using the CMS-1500/837P format.
• Timely Filing: Claims must be submitted within 365 days of the date of service to be eligible for Medicaid reimbursement.
• Procedure Codes: Billed using EOHHS-published HCPCS codes for Supported Employment (e.g., T2019 or similar state-designated codes).
• Prior Authorization: Services must be linked to an active prior authorization generated by the BHDDH tier funding allocation.
• Rate Setting: Reimbursement rates are established by EOHHS and published in the HCBS fee schedule on the EOHHS website.

9. Approval Sequence and Timeline

Becoming a provider is a sequential process that cannot be expedited, as Medicaid enrollment is hard-gated behind BHDDH licensure. The entire process from initial application to first claim submission typically takes 4 to 6 months.

Delays most commonly occur during the BHDDH policy review phase or if the physical location fails the initial fire safety inspection.

• Step 1: Agency secures a physical location in RI and obtains a fire safety certificate (Weeks 1-4).
• Step 2: Submission of the DDO Application with the "Employment Services" box checked to BHDDH OLS (Week 4).
• Step 3: BHDDH desk review of policies and on-site inspection of the facility (Weeks 5-12).
• Step 4: BHDDH issues the formal DDO License (Week 13).
• Step 5: Agency submits the Medicaid enrollment application via the RI Provider Portal (Week 14).
• Step 6: Gainwell/EOHHS processes enrollment, issues Medicaid ID, and agency begins billing (Weeks 16-20).

10. Common Denials and Survey Findings

Applications for DDO licensure are frequently returned if the agency's policies do not explicitly align with Rhode Island's Employment First mandate and the DOJ Consent Decree requirements. Generic HCBS policies imported from other states will be rejected.

During post-enrollment audits, EOHHS and BHDDH frequently recoup funds if employment specialists lack the required ACRE/CESP certifications or if progress notes fail to demonstrate actual job development or coaching activities.

• Policy Misalignment: Denials due to policies that allow for sub-minimum wage or segregated work without proper variance protocols.
• Missing Certifications: Audit findings for deploying job coaches who have not completed required employment-specific training.
• Incomplete Background Checks: Citations for allowing staff to work before the RI Attorney General BCI check is fully cleared.
• Documentation Gaps: Recoupments for billing 15-minute units without corresponding start/stop times and detailed narrative notes.
• Location Non-Compliance: Application rejection if the physical office is not fully ADA accessible or lacks a valid fire certificate.

11. Key Contacts and Resources

Providers should rely on official state portals and designated training networks to maintain compliance. BHDDH and EOHHS provide distinct resources for programmatic and billing support.

The Sherlock Center on Disabilities at Rhode Island College is also a primary resource for ACRE training and Employment First technical assistance in the state.

• BHDDH Office of Licensure and Standards: For DDO application questions (https://bhddh.ri.gov/developmental-disabilities/providers/licensure-and-standards).
• RI Medicaid Provider Portal: For enrollment and claims (https://www.riproviderportal.org).
• EOHHS Provider Manuals: For HCBS billing guidelines (https://eohhs.ri.gov/providers-partners/provider-manuals-guidelines).
• Ticket to Work Help Line: For benefits counseling resources (https://choosework.ssa.gov/).
• Paul V. Sherlock Center on Disabilities: For employment specialist training and ACRE certification (https://www.ric.edu/department-directory/paul-v-sherlock-center-disabilities).

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