ID/A Associations Urge ODP Action on Community Participation Support (CPS)

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.