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Billing

RCPA, along with The Alliance CSP, The Arc of Pennsylvania, MAX Association, PAR, and The Provider Alliance, submitted a joint letter to ODP Deputy Secretary Kristin Ahrens outlining recommended improvements to Community Participation Support (CPS). The letter highlights policy and regulatory barriers affecting person-centered services, workforce stability, and provider sustainability, and urges ODP to pursue near-term solutions through policy clarification or regulatory waivers.

Key recommendations include:

  • Planning and Coordination Billing: Allow billing for planning and coordination while CPS services are delivered and permit billing at ratios aligned with individuals’ actual support needs (e.g., 1:1, 1:2, 1:3). Associations recommend a new billing code/modifier or a statewide ODP announcement.
  • Program Specialist Education Requirements: Align education requirements for program specialists in Chapters 2380 and 2390 with Life Sharing and unlicensed residential models by permitting a high school diploma plus six years of ID/A experience, ideally through a blanket waiver announced via ODP Bulletin.
  • Dual Licensure for Chapter 2380 Programs: Eliminate dual licensure with the Department of Aging for providers billing exclusively to ODP when serving individuals age 60 and over, and remove the age cap of 59 in Chapter 2380 through regulatory change or waiver.
  • Rounding of 15-Minute Units: Allow rounding of 15-minute service units to reduce administrative burden and align with Office of Long-Term Living practices.

The associations stress that these changes are essential to sustaining safe, meaningful, and person-centered CPS services. RCPA will continue advocacy with ODP and provide updates as they are available.

For Questions or Additional Information
Please contact Tim Sohosky for any follow-up or inquiries related to this update.

On September 15, 2025, the Office of Developmental Programs (ODP) leadership conducted their fourth SCO Performance-Based Contracting educational session. This session focused on Pay for Performance (P4P) and billing systems changes ODP anticipates. The slide deck for the session can be found here.

The full recording of the session will be posted at a later date to the ODP Performance-Based Contracting (PBC) Resource Page.

Please direct any questions or feedback to Tim Sohosky, RCPA IDD Division Director.

The Office of Developmental Programs (ODP) has shared ODPANN 25-087. This communication is to inform 100% community location-based Community Participation Support (CPS) providers (Specialty 525) of CPS Facility procedure codes available in HCSIS to permit billing for groups of more than 3 individuals as well as to provide guidance on the planning and coordination component of the CPS service.

Please view the announcement for additional information and details.

Photo by Markus Winkler on Unsplash

Due to delays in Individual Support Plan revisions and other factors impacting provider billing, ODP has extended the time period for providers to submit claims for services.

As indicated in ODP Announcement 24-084: Publication of Final Rates Effective Starting Fiscal Year 2024-2025 and Operational Guidance, page 8 noted, “In November, ODP will process a gross adjustment for any fee schedule services billed during the 1st quarter of the fiscal year. This gross adjustment will compensate providers for the rate differential effective July 1, 2024.”

This is a reminder to all providers to bill for any services rendered from July 1, 2024, through September 30, 2024. ODP will be compensating providers, via gross adjustments, for the difference between the rate billed and the updated fee schedule rate for dates of service rendered during the period July 1, 2024, through September 30, 2024. ODP anticipates processing gross adjustments on Remittance Advices dated Monday, December 23, 2024, to ensure all billing for dates of service July 1, 2024, through September 30, 2024, has been completed. Paid claims data in Remittance Advices between July 1, 2024, and November 18, 2024, will be used as the basis for the gross adjustment.

For questions on how to resolve billing errors for services, contact ODP Claims Resolution.

As indicated in ODP Announcement 24-084: Publication of Final Rates Effective Starting Fiscal Year 2024-2025 and Operational Guidance, page 8 noted, “In November, ODP will process a gross adjustment for any fee schedule services billed during the 1st quarter of the fiscal year. This gross adjustment will compensate providers for the rate differential effective July 1, 2024.”

This is a reminder to all providers to bill for any services rendered from July 1, 2024, through September 30, 2024. ODP will be compensating providers, via gross adjustments, for the difference between the rate billed and the updated fee schedule rate for dates of service rendered during the period July 1, 2024, through September 30, 2024. ODP anticipates processing gross adjustments at the end of November 2024 to ensure all billing for dates of service July 1, 2024, through September 30, 2024, has been completed. Paid claims data in Remittance Advices between July 1, 2024, and November 4, 2024, will be used as the basis for the gross adjustment.

For questions on how to resolve billing errors for services, contact ODP Claims Resolution.

The Pennsylvania Department of Human Services released Medical Assistance Bulletin 99-24-03 on May 28, 2024, detailing updates to the Medical Assistance (MA) Program Fee Schedule based on the 2024 Healthcare Common Procedure Coding System (HCPCS) changes. These updates include new codes such as 90867, 90868, and 90869 for transcranial magnetic stimulation (TMS) treatment billing, along with additional modifications to other procedure codes, setting of limitations, fee adjustments, and new prior authorization requirements effective from the same date. This bulletin applies to all providers serving MA beneficiaries under the Fee-for-Service system and those in the MA Managed Care system should contact their respective organizations for specific billing guidance.

For more detailed information, read the full bulletin here.

If you have any other questions, please contact RCPA COO and Policy Director Jim Sharp.

Image by Dirk Wouters from Pixabay

The Centers for Medicare and Medicaid Services (CMS) is conducting a study to help them improve your experience with Medicare program and billing resources. Share your thoughts with them by taking this survey today. Responses are confidential, and the survey should take about 15 minutes to complete.

CMS thanks you for your time and valuable feedback.

The Office of Developmental Programs (ODP) recently shared a One Page Reference for Supports Coordination (SC) Billing for Cross-Systems Meetings. The reference document was developed to help Supports Coordinators in determining when to bill for a multi-agency meeting. If the SC facilitates the meeting, it is a billable activity. If the SC is not the facilitator of the meeting but provides information about resources or ODP services in order to better serve the individual and their support needs for more than 15 minutes, they can bill for the time that they were providing information.