West Virginia - Prevocational Services — Licensing, Medicaid Enrollment and Startup Requirements
Last reviewed: 2026-09-10
West Virginia funds Prevocational Services primarily through the Title XIX Intellectual/Developmental Disabilities (I/DD) Waiver, requiring providers to first obtain a Behavioral Health Center license from the Office of Health Facility Licensure and Certification (OHFLAC) under W.Va. Code of State Rules 64-11. The service delivers time-limited training in general work readiness, including attendance, task completion, safety, and workplace behavior, rather than job-specific skill training.
Before submitting a Medicaid enrollment application to the Bureau for Medical Services (BMS), prospective agencies must secure this OHFLAC licensure, which mandates a comprehensive policy review and an initial on-site life safety and programmatic survey. Providers then enroll through the WVMMIS portal, submitting proof of OHFLAC licensure and WV CARES background check compliance to activate their billing privileges.
1. Service Definition and Scope
In West Virginia, Prevocational Services provide learning and work experiences, including volunteer work, where the individual can develop general, non-job-task-specific strengths and skills that contribute to employability in paid employment in integrated community settings. Services are expected to occur over a defined period of time with specific outcomes to be achieved.
The service is distinct from Supported Employment, as it focuses on foundational skills like following directions, attending to tasks, workplace problem solving, and safety, rather than the mechanics of a specific job.
- Target Population: Individuals enrolled in the I/DD Waiver seeking to build foundational work skills.
- Core Activities: Training in attendance, task completion, workplace safety, and interpersonal relations.
- Setting Requirements: Must comply with the CMS HCBS Settings Rule, ensuring integration and access to the greater community.
- Time Limits: Authorized for a specific duration based on the member's individualized service plan (ISP) goals.
- Exclusions: Cannot duplicate services available under the Rehabilitation Act of 1973 or the Individuals with Disabilities Education Act (IDEA).
2. Regulatory and Oversight Agencies
The Office of Health Facility Licensure and Certification (OHFLAC) acts as the primary regulatory body for facility and agency licensure in West Virginia. They conduct the initial and ongoing surveys required to maintain a Behavioral Health Center license.
The Bureau for Medical Services (BMS) administers the Medicaid program, sets policy, and manages provider enrollment through its fiscal agent.
- Licensing Agency: Office of Health Facility Licensure and Certification (OHFLAC) (https://ohflac.wv.gov)
- Medicaid Authority: Bureau for Medical Services (BMS) (https://bms.wv.gov)
- Background Check Authority: West Virginia Clearance for Access: Registry & Employment Screening (WV CARES) (https://wvcares.wv.gov)
- Enrollment Portal: West Virginia Medicaid Management Information System (WVMMIS) (https://www.wvmmis.com)
3. Gatekeeping Prerequisites: Who Can Even Apply
West Virginia requires an active Behavioral Health Center license from OHFLAC before BMS will accept a Medicaid provider enrollment application for Prevocational Services. There is no Certificate of Need (CON) required for this specific HCBS waiver service, but the OHFLAC licensure process serves as the structural gatekeeper.
Applicants must establish a physical location in West Virginia that meets Life Safety Code standards and must register their business with the West Virginia Secretary of State.
- Mandatory Licensure: OHFLAC Behavioral Health Center license required prior to Medicaid enrollment.
- Business Registration: Must be registered and in good standing with the West Virginia Secretary of State.
- NPI Requirement: Must obtain a Type 2 National Provider Identifier (NPI) matching the exact legal entity name.
- Background Clearance: Must establish an account with WV CARES for mandatory fingerprint-based background checks before hiring staff.
4. Licensure and Certification Requirements
Providers must comply with W.Va. Code of State Rules 64-11, which governs Behavioral Health Centers. The application process requires submission of detailed operational policies, organizational charts, and floor plans for any facility-based service locations.
OHFLAC conducts an initial on-site survey to verify compliance with programmatic rules and the NFPA Life Safety Code before issuing the initial license.
- Rule Citation: W.Va. CSR 64-11 Behavioral Health Centers.
- Policy Manual: Must submit comprehensive policies covering member rights, incident management, and quality assurance.
- Life Safety Code: Facility locations must pass an OHFLAC Life Safety inspection.
- Initial Survey: An on-site programmatic and environmental survey is required before license issuance.
- License Renewal: Licenses are typically issued for one year and require annual renewal and periodic resurveys.
5. Medicaid Provider Enrollment
Once licensed by OHFLAC, providers submit their enrollment application through the WVMMIS provider portal. Enrollment is governed by BMS Chapter 300 (Provider Participation Requirements) and the specific waiver manual.
Providers must pay the federal Medicaid application fee (or provide proof of payment to Medicare or another state) and sign the West Virginia Medicaid Provider Agreement.
- Enrollment System: WVMMIS Provider Portal (https://www.wvmmis.com).
- Required Attachments: Copy of current OHFLAC license, W-9, and IRS CP-575.
- Application Fee: Subject to the CMS-mandated institutional provider application fee unless waived.
- Site Visits: BMS or its fiscal agent may conduct pre-enrollment site visits as part of federal screening requirements.
- Revalidation: Providers must revalidate their Medicaid enrollment every five years.
6. Staffing, Training and Background Checks
All staff providing Prevocational Services must clear a fingerprint-based background check through WV CARES prior to having direct contact with members. Providers must maintain a roster in the WV CARES system.
Direct Support Professionals (DSPs) must complete state-mandated training, including CPR, First Aid, and specific modules on member rights, incident reporting, and the HCBS Settings Rule.
- Background Checks: Mandatory processing through WV CARES (Chapter 700 rules).
- Basic Training: CPR and First Aid certification required prior to independent service delivery.
- Waiver Training: Must complete I/DD Waiver-specific training modules as outlined in the BMS manual.
- Supervisor Qualifications: Programs must be overseen by a qualified professional meeting the state's definition of a Qualified Intellectual Disabilities Professional (QIDP).
- Personnel Files: Must retain transcripts, training certificates, and WV CARES clearance letters for all staff.
7. Documentation, Policies and Records
BMS requires providers to maintain specific, detailed records for all services rendered to Medicaid members. Documentation must clearly link the activities performed during the shift to the goals outlined in the member's ISP.
All records must be retained for a minimum of five years and be readily available for audit by BMS, OHFLAC, or federal reviewers.
- Service Notes: Must include member name, date, specific activities, and signature/credentials of the staff.
- Time Tracking: Exact start and stop times are strictly required for every billed shift.
- Retention Period: All clinical and billing records must be kept for at least five years.
- Incident Reporting: Must utilize the state's Incident Management System for critical incidents.
- Policy Updates: Agency policies must be reviewed annually and updated to reflect current BMS and OHFLAC rules.
8. Billing, Rates and Claims
Prevocational Services are billed to West Virginia Medicaid through the WVMMIS system using specific HCPCS codes (typically T2015) and modifiers designated in the I/DD Waiver manual. Services must be prior-authorized by the state's Utilization Management contractor.
Rates are established by BMS and published in the I/DD Waiver fee schedule. Providers cannot bill for time spent on staff breaks or time when the member is not actively participating in the service.
- Billing System: Claims are submitted electronically via WVMMIS.
- Prior Authorization: Required from Kepro/Acentra before services can be billed.
- HCPCS Code: Billed using state-designated codes (e.g., T2015) as published in the current fee schedule.
- Unit Definition: Typically billed in 15-minute increments; partial units cannot be rounded up.
- Rate Publication: Current rates are posted on the BMS website under the Behavioral Health/Waiver section.
9. Approval Sequence and Timeline
The approval process is strictly sequential. An agency cannot apply for Medicaid enrollment until the OHFLAC license is in hand, and cannot bill until WVMMIS enrollment is approved and prior authorizations are secured.
The entire process from entity formation to first billable claim typically takes 6 to 9 months, heavily dependent on the provider's readiness for the OHFLAC initial survey.
- Step 1: Corporate formation and WV Secretary of State registration.
- Step 2: Submission of OHFLAC Behavioral Health Center application and policies.
- Step 3: OHFLAC on-site Life Safety and programmatic survey.
- Step 4: Receipt of OHFLAC license and WV CARES account activation.
- Step 5: Submission of WVMMIS Medicaid enrollment application.
- Step 6: Approval, contracting, and receipt of member prior authorizations.
10. Common Denials and Survey Findings
During OHFLAC surveys, providers frequently face citations for incomplete policy manuals or failure to meet Life Safety Code requirements in facility-based settings. BMS audits commonly target documentation deficiencies.
Medicaid enrollment applications are most often delayed due to mismatched legal names between the IRS, Secretary of State, NPI registry, and OHFLAC license.
- Documentation Errors: Missing exact start and stop times on service notes.
- Background Lapses: Allowing staff to work before receiving official WV CARES clearance.
- Name Mismatches: Legal entity name discrepancies across federal and state documents.
- Training Gaps: Missing annual CPR/First Aid renewals in personnel files.
- Settings Rule: Failure to demonstrate that the prevocational setting is integrated into the broader community.
11. Key Contacts and Resources
Prospective providers should regularly consult the official state websites for the most current manuals, fee schedules, and regulatory updates. The BMS and OHFLAC portals are the primary hubs for compliance.
Utilizing the state's published provider manuals (Chapter 300 and the specific Waiver chapter) is essential for maintaining operational compliance.
- OHFLAC: https://ohflac.wv.gov
- Bureau for Medical Services (BMS): https://bms.wv.gov
- WVMMIS Provider Portal: https://www.wvmmis.com
- WV CARES: https://wvcares.wv.gov
- WV Secretary of State: https://sos.wv.gov
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