Performance-Based Contracting Frequently Asked Questions
This FAQ contains questions not answered in the Process Details document. Please review this document if your questions are not answered below.
Performance-Based Contracting Frequently Asked Questions (FAQ) for Individuals and Families
FAQ Last Updated: 10/01/2025
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General
>What will happen after a provider submits their data in the MyPBC Data Submission Portal?
ODP will review the provider’s submission based on the tier for which the provider submitted. If the provider meets all of the measures for the tier, the provider will receive written notification of their tier determination.
If a provider does not meet all of the measures for the tier in which they submitted, the provider will be notified in writing of their tier determination, which will include a list of unmet measures and reasons those measures were not met.
If a provider believes the Department made an error in the tier determination (applies only to advanced tiers), the provider will have the opportunity to submit information supporting their position. This is not an opportunity to correct an unmet measure, rather an opportunity for the provider to submit information that supports their position that the Department made an error when determining if a measure was met.
Upon receipt of the provider’s materials, the Department will reexamine its findings and the provider will be notified in writing regarding the updated tier determination, including measure(s) evaluations that were changed or remain the same based on the information submitted.
>Can providers apply for the Select or Clinically Enhanced tiers even though they don’t meet a performance standard but will submit a plan of correction to get back into compliance?
Providers should only apply for the tier for which they know they will meet the required measures. CAPs will not be used in this manner.
>How does a new residential provider get a tier determination after the start of the PBC review cycle?
Effective January 1, 2025, when ODP determines that there is a need for additional Residential Habilitation, Life Sharing, or Supported Living providers, new residential provider applicants will be invited to qualify for enrollment through a competitive request for application process. In the meantime, we strongly encourage applicants to enroll to provide non-residential services to gain the experience necessary for successful residential service provision. This will also help providers meet the current qualification requirement to have two years’ experience providing non-residential services as described in ODPANN 24-008: Clarification Regarding New Qualification Requirements for Agencies That Want to Enroll to Provide Residential Services.
This only applies to providers that are not enrolled and qualified to provide Residential Habilitation, Life Sharing, or Supported Living services in the Consolidated and/or Community Living Waivers by December 31, 2024.
DATA SUBMISSION PORTAL
>If a provider knows they will be in the Primary Tier, are they required to submit for PBC?
Yes, all providers of residential services through the Consolidated and Community Living Waivers are required to submit data and documentation for tier determination, regardless of the tier for which they meet the criteria.
>When submitting data and documentation for tier determination, which individuals and staff should we include?
Performance-Based Contracting only applies to Residential Habilitation, Life Sharing, and Supported Living services provided through the Consolidated and Community Living Waivers. Providers should only include information for individuals receiving one of these services and staff involved in the provision of one of these services through the Consolidated and Community Living Waivers.
>On average, how long does it take to upload required data and documentation to complete a submission in the MyPBC Portal?
The average time for data and documentation submission varies by tier as follows:
– Primary = 2 hours
– Select = 3 hours
– Clinically Enhanced = 3 hours
COMPOSITE SCORING
>Please provide additional details regarding composite scoring. What percentage must be met for measures that are part of composite scoring?
n the spreadsheet with the Process Details, providers will see a column labeled “Composite Category.”
– If NA appears in the column, the measure stands alone and is not part of a composite category. The provider must meet the measure in order to obtain the desired tier.
– If CN appears in the column, the measure is part of the Complex Needs composite category. Providers need to achieve at least 70% of the measures in this category.
– If DO appears in the column, the measures are part of the Data to Outcomes composite. Providers need to achieve at least 80% of the measures in this category.
– If IM appears in the column, the measure is part of the Incident Management composite category.
– If IM appears in the column, the measure is part of the Incident Management composite category. Providers need to achieve at least 60% of the measures in this category.
>Are all measures given the same weight in composite scoring?
Yes. As an example, to meet the Clinically Enhanced tier there are 8 measures in the Data to Outcomes (DO) composite category. Each measure equals 12.5%. Providers will need to meet at least 7 of the 8 measures in the Data to Outcomes composite category to meet the Clinically Enhanced tier requirements (score of 87.5%).
>How does composite scoring work for Clinically Enhanced Medical Support versus Clinically Enhanced – Dual Diagnosis?
If your organization is applying for the Clinically Enhanced tier, then the measure applies whenever any of the following appear in the “Applicability” column:
– ALL (Applies to all tiers)
– C (Applies to Clinically Enhanced only)
– SC (Applies to Select and Clinically Enhanced)
If you cross-reference the Composite Categories for the measures that apply to ALL, C, and SC, you will note that:
– CN has 8 measures.
– D has 8 measures.
– IM has 3 measures.
Therefore, to meet or exceed the thresholds for each Composite Category, a provider that is applying for the Clinically Enhanced tier must meet at least
– 6 CN measures (70%), and
– 7 DO measures (80%), and
– 2 IM measures (60%).
Additionally, all Clinically Enhanced providers must fall into one of the following categories:
– Clinically Enhanced for Medical Support,
– Clinically Enhanced for Dual Diagnosis, OR
– Clinically Enhanced for Medical Support and Dual Diagnosis
You will note that each measure that applies to the Clinically Enhanced tier has one of the following codes in the “Clinically Complex Category” field:
– NA
– BS
– MS
To be Clinically Enhanced for Medical Support, the provider must meet:
– All “NA” measures / composite measures
– CN-M.01.1
– CN-M.01.2
But does not have to meet:
– CN-DD/Bx.01.2
– CN-DD/Bx.02.2-9
– CN-DD/Bx.03.4-5
To be Clinically Enhanced for Dual Diagnosis, the provider must meet:
– All “NA” measures / composite measures
– CN-DD/Bx.01.2
– CN-DD/Bx.02.2-9
– CN-DD/Bx.03.4-5
But does not have to meet:
– CN-M.01.1
– CN-M.01.2
To be Clinically Enhanced for Medical Support and Dual Diagnosis, the provider must meet:
– All “NA” measures / composite measures
– CN-M.01.1
– CN-M.01.2
– CN-DD/Bx.01.2
– CN-DD/Bx.02.2-9
– CN-DD/Bx.03.4-5
However, the composites still apply within each category.
PERFORMANCE MEASURES: ACCESS
>For measures AC.01.2 and AC.01.3 what is the definition of referral?
A provider referral is the process by which the SC connects an individual in need of residential services with qualified providers. At minimum, each referral must include the identified service type, summary of medical and behavioral supports needed, and the ISP with PII redacted unless consent is given.
PERFORMANCE MEASURES: ADMINISTRATION
>For measure ADM.01.1, will residential providers be required to submit financial statements each year as part of the tier determination process? If yes, what fiscal year would need to be covered by the financial statements during the next tier determination process in 2026?
Residential providers will be required to submit financial statements (audited if available) each year as part of the Performance-Based Contracting tier determination process. Guidance for the submission that will occur in 2026 will be as follows:
– If your agency had a financial audit completed within the past 12 months, submit copies of this audit.
– If your agency did not have an audit completed, submit current financial statements (at minimum profit/loss statements AND balance sheets) reflective of your most recently completed fiscal year.
>For measure ADM.01.1, providers are required to report the names of officers and owners that have had any criminal convictions. What positions would be considered “officers” for this measure? How often should providers review criminal convictions for officers and owners?
The term “officer” includes any person who is part of the governing body or appointed to manage the agency as an agent of the governing body. The term includes, but is not limited to, board members, President, Vice President, Chief Operations Officer, Chief Financial Officer, Treasurer, and Secretary. Residential providers will be required to disclose the history and status of criminal convictions of officers and owners on an annual basis for compliance with performance measures.
>For measure ADM.01.2, does the Board of Directors, advisory committee or subcommittee need to be a fiduciary board? If the provider has an individual with intellectual/developmental/autism on the Board of Directors or on the advisory committee or subcommittee as a person with lived experience, is it required that the individual be receiving residential services?
The provider is not required to have or submit information from a fiduciary board. The documentation should come from a governing body, which could include an advisory committee, a subcommittee, or group of owners gathered to deliberate and make organizational decisions.
When providers choose to include at least one individual with intellectual/developmental disabilities/autism on the Board of Directors, there is no requirement for that individual to be receiving ODP services.
PERFORMANCE MEASURES: SUPPORTING INDIVIDUALS WITH COMPLEX NEEDS
>For measure CN-C.01.1, will professionals such as Licensed Social Workers and Certified Registered Nurse Practitioners be included in the current ratio of licensed/credentialed clinical staff to demonstrate the size of the agency’s multidisciplinary clinical team?
ODP will include the following professional licensed entities in measure CN-C.01.1:
– Licensed Associate Professional Counselor(s) (LAPCs)
– Licensed Social Worker(s) (LSWs) which require a Master’s Degree or Doctoral Degree
– Certified Registered Nurse Practitioner(s) (CRNPs)
– Licensed Associate Marriage and Family Therapists (LAMFTs)
– Licensed Marriage and Family Therapist(s) (LMFTs)
>For measure CN-C.01.2, are providers required to manually calculate and report the average health care level (HCL) and needs level (NL) for individuals receiving residential services or will ODP provide this information?
This measure solely applies to the Clinically Enhanced tier. Providers submitting for the Clinically Enhanced tier are not required to report this information. This information will be calculated by ODP as outlined in the Process Details: ODP will review Supports Intensity Scale (SIS) NL and Health Risk Screening Tool (HRST) data to determine provider performance in this area.
– First portion (SIS NL):
Numerator: Total needs level of all persons supported by the provider as of a specific date (Excluding Supported Living and Life Sharing)
Denominator: Total number of people supported by provider in residential services as of the same specific date (Excluding Supported Living and Life Sharing)
– Second portion (HRST HCL)
For this to be measured, all HRST screenings must be up to date (within statutory frequency) as of the specified date.
Numerator: Total HCL of all persons supported by the provider as of a specific date (Excluding Supported Living and Life Sharing)
Denominator: Total number of people supported by provider in residential services as of the same specific date” (Excluding Supported Living and Life Sharing)
If a provider wishes to obtain health care level information in advance of submitting for the Clinically Enhanced tier, the provider can pull the health care level of every person served by the agency in aggregate via one of the available standard reports or by report generation in the Health Risk Screening Tool (https://paodp.hrstapp.com/) using the following path: HRST > Persons Served > Reports > Standard Reports > Distribution > HCL Distribution. The same information can be found in HRST > Persons Served > Reports > Standard Reports > Compliance > Record Activity with Provider.
>For measure CN-C.01.3, can ODP provide an example of how a provider should document tracking and use of data relating to the HRST scoring item E. Clinical Issues Affecting Daily Life?
The following is an example of how a provider could use HRST to measure daily interruptions:
The provider may notice that people are often having interruption to daily activities due to becoming sick with influenza or other contagious diseases. The provider could discuss with their healthcare team ways to help reduce the likelihood of influenza, and based on recommendations, implement training on proper hand washing techniques or increase awareness of and participation in flu vaccination and therefore reduce number of interruptions in daily activities due to influenza in the future.
As a reminder, “clinical issues” is a discrete metric in HRST.
>For measure CN-C.02.1, would a Behavioral Support Specialist employed or contracted by the agency meet the requirement for the agency to have established professional relationships to support individuals served?
The residential provider’s Behavioral Support Specialist does not meet this requirement. To meet this requirement, the residential provider must describe external established professional relationships with agencies or professionals such as a relationship with a local behavioral health provider, peer specialist, and/or primary care health/medical provider that has training/experience in autism or developmental disabilities. If the residential provider does not have any external established professional relationships in the community/communities they serve, this should be reported in the provider’s PBC submission. ODP expects that residential providers will establish these relationships to ensure individuals have access to all needed medical and mental health assessment and treatment. This is above and beyond services required by residential service definitions.
>For measure CN-C.02.1, would the Specialty Telehealth and Assessment Team service count as an established professional relationship since those medical professionals already have experience in autism / developmental disabilities?
While the Specialty Telehealth and Assessment Team (STAT) service meets the requirements of the measure, ODP expects residential providers to have additional external established professional relationships in the community/communities they service to ensure all individuals have access to all needed medical and mental health assessment and treatment.
>For measure CN-DD/Bx.01.1, what information would need to be covered in a course that is an “equivalent basic course on effectively supporting individuals with Autism Spectrum Disorder”? Do providers need to submit a description of training that meets these requirements for ODP review and approval?
An equivalent basic course on effectively supporting individuals with Autism Spectrum Disorder must cover the following topics:
– The core deficits in individuals with autism. Co-occurring mental and physical conditions, as they present in individuals with autism. How deficits can change dependent on the environment, daily routines/activities, trauma, medical/psychiatric presentations, and/or supports present/absent in a person’s life.
– Basic information about Applied Behavioral Analysis, including common terms, basic principles used to change behavior and teach new skills. An overview of the process and use of Functional Behavioral Assessments to drive the development and implementation of a Behavioral Support Plan.
– Information on identifying and teaching adaptive skills used in everyday life, the importance of adaptive and independent living skills, and challenges that may arise when teaching adaptive skills to individuals with autism.
– Community engagement, including how community engagement plays a role in supporting individuals with autism and their families. Information about how to best support participants in making informed choices and decisions, while also being aware of the dignity of risk.
– How to support participants in finding and maintaining meaningful employment and educational opportunities. This includes the benefits of employment and postsecondary education in a participant’s life, available vocational and educational supports, and the impact of employment on benefits.
– Information on the basic social and communication deficits associated with autism, and challenges individuals with autism may have in navigating social relationships. Methods that can be used to help individuals improve their social skills. Recognition of the differences in language and communication.
As outlined in the attestation, the provider is expected to produce documentation demonstrating the Residential Provider meets the requirements for all items checked upon request by ODP.
>For measure CN-DD/Bx.01.1, the attestation requires that staff (DSP, FLS, and program managers) complete training on Autism Spectrum Disorder. Could you provide clarification or a definition about which positions are covered as program managers?
Program managers are staff who oversee and coordinate the operations and activities in one or more residential homes. Program managers include program specialists, house managers, or other agency supervisory or management staff with DSPs and/or FLSs in their chain of command. Due to the importance of this training, ODP encourages providers to have all staff complete training on Autism Spectrum Disorder (i.e., SPeCTRUM or equivalent basic course on effectively supporting individuals with Autism Spectrum Disorder).
>For measure CN-DD/Bx.01.2, what is the definition of behavioral support hours? Who is considered behavior support staff for this measure?
Behavioral support hours are hours spent on activities outlined in the behavioral support service definition in the Consolidated and Community Living Waivers. Behavior support staff are staff (employed or contracted) who meet the residential provider qualification requirements in the Consolidated and Community Living Waivers for behavioral specialists
>For measure CN-DD/Bx.02.7, what is the definition of polypharmacy?
While there are varying definitions of polypharmacy, the term typically refers to the simultaneous use of multiple drugs (such as 5 or more) by a single individual for one or more conditions, or multiple drugs used by an individual for a single ailment or condition. Since this measure is evaluated by providers’ submission of the use of data to impact individual outcomes over time based on measurable factors, the provider may determine how they define polypharmacy as part of their submission to ODP.
>For measure CN-DD/Bx.03.2-3, can ODP please provide resources and examples for providers to find specialized trauma informed training for staff and activities for staff?
This measure applies to the Select and Clinically Enhanced tiers. Training and activities to support trauma-informed care for individuals with intellectual disabilities or autism are any trainings or activities that raise awareness of trauma and its impact on development, the establishment of safe environments, emotional regulation techniques, and building trust between individuals and caregivers.
The following is not an exhaustive list but a few examples of the many resources available to meet this measure, including Health Care Quality Units (HCQUs), HEAL PA, and the Office of Mental Health and Substance Abuse Services (OMHSAS).
– MyODP: HCQU-Main | MyODP (https://www.myodp.org/mod/page/view.php?id=7699)
– Course: 2024 – Dual Diagnosis Curriculum | MyODP (https://www.myodp.org/course/view.php?id=2390)
– Resources – Office of Mental Health and Substance Abuse Services (https://myomhsas.org/category/communications/resources/)
– HEAL PA (https://www.healpa.org/)
– Wellness Recover Action Plan (WRAP) https://www.wellnessrecoveryactionplan.com/
Note: The measure does include training/activities for individuals as well as staff. This was a commonly missed response area during the first submission period.
>What “crisis prevention and de-escalation training programs” are approved by ODP to meet measure CN-DD/Bx.03.4?
The following crisis prevention and de-escalation training programs meet measure CN-DD/Bx.03.4:
– Ukeru
– Crisis Prevention Institute (CPI)
– Collaborative and Protective Solutions (CPS)
– Mandt System®
– Non-Violent Crisis Intervention® Training
– Safe and Positive Practices/Approaches
– Safe Crisis Management (SCM)
– Quality Behavioral Solutions (QBS) – Safety Care
– Therapeutic Options
NOTE: “Positive Behavioral Interventions and Supports (PBIS)” was removed from the original list because PBIS is an approach to behavioral intervention and not a curriculum. One cannot get liability coverage through PBIS nor can one be certified in PBIS in the same way these can be accomplished in other curricula listed.
PERFORMANCE MEASURES: CONTINUUM OF SERVICES
See Residential Performance Standards
PERFORMANCE MEASURES: DATA MANAGEMENT
>Does the requirement to use electronic medication administration records apply to Life Sharing and Supported Living services to meet measure DM.02? Are providers required to use electronic medication administration records for every individual to meet measure DM.02?
The requirement to have an Electronic Health Record applies to Life Sharing and Supported Living providers in the Select or Clinically Enhanced Tiers. ODP allows agency use of electronic medication administration records to meet the minimum standard. Electronic medication administration records are often web-based, cloud services that can be accessed from any device that supports a web-browser such as a computer, laptop, or mobile-device, and would be used as appropriate to meet the support needs of the individual receiving residential services.
Electronic medication administration records are not required to be used for every individual receiving residential services. The residential provider must have electronic medication administration records available to support individuals and residential direct support professionals in achieving outcomes related to appropriate medication administration.
ODP expects that Electronic Health Records will be available for use by all individuals who receive residential services and deployment is person centered.
PERFORMANCE MEASURES: EMPLOYMENT
See Residential Performance Standards
PERFORMANCE MEASURES: QUALITY
>For measure QI.02.5, what timeframe does the sample report submitted need to cover?
The provider can choose to submit an operational quarterly report or quality report that covers either the most recently completed Calendar or Fiscal Year.
PERFORMANCE MEASURES: REGULATORY COMPLIANCE
See Residential Performance Standards
PERFORMANCE MEASURES: RISK MANAGEMENT
>Can ODP publish the calculations and the percentage results for each provider for RM-IM.01.1, RM-IM.01.2, and RM-IM.01.3?
Providers can access their data for RM.IM.01.2 and RM.IM.01.3, through the Enterprise Incident Management dashboard. ODP recommends reviewing the Incident Reporting Overview Dashboard Training Guide for more information.
ODP will publish status by MPI for RM-IM.01.1 – 01.3.
>For measure RM-IM.01, will ODP share all unreported incidents with each provider?
The provider will receive notification about an unreported incident from the applicable Administrative Entity. This number divided by the total number of Provider Type 52 incidents submitted during the time period under review will produce the percent of unreported incidents.
If a provider receives notification that this measure was not met during ODP’s assessment for tier determination, the provider may use the Performance-Based Contracting Resolution Process to demonstrate using their own records what they believe the actual percentage to be. ODP will then review the submission to determine if the tier determination should be changed.
If a provider receives notification that this measure was not met during ODP’s assessment for tier determination, the provider may use the Performance-Based Contracting Data Submission Resolution Process to demonstrate using their own records what they believe the actual percentage to be (see “What will happen after a provider submits their data in the Data Collection Tool?” above). ODP will then review the submission to determine if the tier assignment should be changed.
>For measure RM-IM.01.3, can ODP provider further clarification regarding the “discovery date”?
The discovery date is the date and time that an initial reporter became aware of, or suspected that, a reportable incident occurred.
https://www.pa.gov/content/dam/copapwp-pagov/en/dhs/documents/docs/publications/documents/forms-and-pubs-odp/Bulletin%2000-21-02%20Incident%20Management.pdf
The occurrence dates and discovery dates can be different.
For regulatory compliance and for Performance-Based Contracting measures, ODP relies only on the discovery date and time as that determines when the first section of a report must be submitted.
For regulatory compliance and for Performance-Based Contracting measures, ODP relies only on the discovery date and time as that determines when the first section of a report must be submitted.
PERFORMANCE MEASURES: USE OF REMOTE SUPPORT TECHNOLOGY
See Residential Performance Standards
PERFORMANCE MEASURES: WORKFORCE
>For all workforce measures related to National Alliance for Direct Support Professionals (NADSP) credentialing, once a direct support professional (DSP) or frontline supervisor (FLS) is credentialed, what is the process for maintaining the credential?
NADSP Certification (DSP-I, DSP-II, DSP-III, FLS) requires recertification every two years. By the end of the two-year term, the certified DSP or FLS must complete/submit at least 20 hours of training. This training does not have to be NADSP-Accredited, but no more than 8 of the 20 hours can be from mandatory training requirements. (Certification Renewal Application (DSP I, DSP II, DSP III, FLS) – NADSP)
>For measure WF.03.3, the annual NCI State of the Workforce survey has not yet been released for completion. Can providers upload survey results from the previous year?
The NCI portal will open in February of each year. While we understand that this is a short amount of time to complete the survey, the requirement will remain participation in the most recent NCI State of the Workforce survey.
>For measure WF.03.3, how can providers get a copy of their NCI survey results to upload in the MyPBC Data Submission Portal?
Providers should click on the original link in the invitation email they used to access the survey. If the survey was completed, providers will be brought to this page:
Providers can click on “Review”, then scroll to the bottom of the page to see an option to “PRINT” the responses. This will allow providers to download their responses as a PDF.
PAY FOR PERFORMANCE INITIATIVES
>For the Competitive Integrated Employment Milestone 2 payment, which individuals should providers submit data for? Will ODP verify the accuracy of information submitted by providers?
This payment will be calculated by measuring the difference between the point-in-time number of individuals in competitive integrated employment on January 1, 2025 and December 31, 2025. ODP will verify the accuracy of information submitted by providers based on information about individuals’ competitive integrated employment status in their Individual Support Plans. As a reminder, measure EMP.01.2 requires the provider’s plan for improving competitive integrated employment to include a description of structure/communication plan with the individual’s Supports Coordinator to ensure employment information in the ISP is up-to-date and accurate.
Decision: Change heading title from “payment” to “initiatives”