Performance-Based Contracting Information
This FAQ contains questions not answered in the Implementation Guide or Residential Performance Standards Documents. Please review these documents if your questions are not answered below.
FAQ Last Updated: 01/08/2025
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TIER ASSIGNMENT
ODP will review the provider’s submission based on the tier for which the provider applied.
If the provider meets all of the measures for the tier, the provider will receive written notice that they have been assigned to the tier they applied for.
If a provider does not meet all of the measures for the tier, the following will occur:
If the provider applied for Primary status, the provider will be notified in writing that they have been assigned to the Primary tier, but that corrections are required prior to the next submission period. The notice will include a list of measures that were not met and must be corrected prior to the next submission period.
If the provider applied for Select status, the provider will be notified in writing that they have not met the criteria for Select status. The notice will include a list of measures that were not met.
– If the provider believes the Department made an error in the tier determination, the provider will have the opportunity to provide information supporting their position. Please note that this is not an opportunity to correct an unmet measure, but 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.
~ If an error was made, the provider will be notified in writing that they have been assigned to the Select tier.
~ If no error was made, the provider will be notified in writing that they have been assigned to the Primary tier, and that corrections are required. The notice will include a list of Primary measures that were not met, instructions for what corrections must be made, and dates by which corrections are due.
If the provider applied for Clinically Enhanced status, the Department will review the provider’s submissions to determine whether the provider is eligible for the Select tier.
If the provider is eligible for the Select tier, the provider will be notified in writing that they have not met the criteria for Clinically Enhanced status, but have met the criteria Select tier. The notice will include a list of Clinically Enhanced measures that were not met.
– If the provider believes the Department made an error in the tier determination, the provider will have the opportunity to provide information supporting their position. Please note that this is not an opportunity to correct an unmet measure, but 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.
~ If an error was made, the provider will be notified in writing that they have been assigned to the Clinically Enhanced tier.
~ If no error was made, the provider will be notified in writing that they have been assigned to the Select tier.
If the provider is not eligible for the Select tier, the provider will be notified in writing that they have not met the criteria for Clinically Enhanced status. The notice will include a list of measures that were not met.
– If the provider believes the Department made an error in the tier determination, the provider will have the opportunity to provide information supporting their position. Please note that this is not an opportunity to correct an unmet measure, but 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.
~ If an error was made, the provider will be notified in writing that they have been assigned to the Clinically Enhanced tier.
~ If no error was made, the provider will be notified in writing that they have been assigned to the Primary tier, and that corrections are required. The notice will include a list of Primary measures that were not met, instructions for what corrections must be made, and dates by which corrections are due.
No. A provider should only apply for a tier for which they know they will meet all required measures. Providers will have the opportunity to respond to the Department’s tier determination if they believe an error has been made, but may not correct an unmet measure after the fact (see “What will happen after a provider submits their data in the Data Collection Tool?” above).
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. All providers that are enrolled and qualified to provide residential services by December 31st will be assessed for tier determination in either August 2024 or February/March 2025.
DATA SUBMISSION TOOL
Yes, all providers of residential services through the Consolidated and Community Living Waivers are required to submit data and documentation for tier consideration, regardless of the tier for which they meet the criteria.
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.
COMPOSITE SCORING
On the scoring tool you 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.
– If D appears in the column, the measure is part of the Data Management composite category.
– If IM appears in the column, the measure is part of the Incident Management composite category.
– If WA appears in the column, the measure is part of the Workforce Administration composite category.
In most cases, providers need to achieve at least 70% of the measures from the Complex Needs, Data Management, Incident Management, and Workforce Administration composite categories to obtain the desired tier. In some cases, providers might need to achieve slightly less than 70%, because not meeting one measure will result in a score of slightly less than 70%.
Yes. As an example, to meet the Clinically Enhanced tier there are 6 measures in the Data Management (D) composite category. Each measure equals 16.67%. Providers will need to meet at least 5 of the 6 measures in the Data Management composite category to meet the Clinically Enhanced tier requirements (score of 83%).
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 7 measures.
– D has 6 measures.
– WA has 6 measures.
– IM has 3 measures.
Therefore, to meet or exceed the 70% threshold for each Composite Category, a provider that is applying for the Clinically Enhanced tier must meet at least:
– 5 CN measures, and
– 5 D measures, and
– 5 WA measures, and
– 2 IM measures.
Additionally, all Clinically Enhanced providers must fall into one of the following categories:
– Clinically Enhanced for Medical Support,
– Clinically Enhanced for Behavioral Support (“Dual Diagnosis” in some documents), OR
– Clinically Enhanced for Medical Support and Behavioral Support
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
– CN-DD/Bx.03.3
To be Clinically Enhanced for Behavioral Support, the provider must meet:
– All “NA” measures / composite measures
– CN-DD/Bx.01.2
– CN-DD/Bx.02.2
– CN-DD/Bx.03.3
But does not have to meet:
– CN-M.01.1
– CN-M.01.2
To be Clinically Enhanced for Medical Support and Behavioral Support, 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
– CN-DD/Bx.03.3
You will note that CN-DD/Bx.01.2 is also a CN measure, so if a Clinically Enhanced provider wants to be Clinically Enhanced for Behavioral Support, they must meet CN-DD/Bx.01.2 even though it is part of a composite measure.
PERFORMANCE MEASURES: CONTINUUM OF SERVICES
See Residential Performance Standards
PERFORMANCE MEASURES: REFERRAL AND DISCHARGE PRACTICES
A referral is any contact initiated by a Supports Coordinator or Administrative Entity with a residential provider that includes a formal request for residential services, the individual’s ISP, and/or any other record that would be used by the provider to determine suitability for residential service by the provider.
PERFORMANCE MEASURES: WORKFORCE
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)
Providers should click on the original link in the invitation email they used to access the survey. If they completed the survey, they will be brought to this page:
Then, they can click on “Review”. At the bottom of the Review page, there is an option to “PRINT” the responses. This will allow providers to download their responses as a PDF.
During the first year of Performance-Based Contracting, providers have broad discretion in what documentation to submit. It is assumed that agencies that have diverse staff with various linguistic and cultural backgrounds engage in some type of training activities specific to the languages and cultures of their staff. This could include activities such as: evaluating language skills, conducting surveys or focus groups in native languages to gather feedback to promote accurate understanding of common terms used in the service system for rendering services to individuals with intellectual disability and autism, providing cultural sensitivity training, using interpreters, utilizing digital platforms that support multiple languages, offering essential training in native languages, and so on. The measure will be met as long as the provider describes their agency’s training activities in relation to the languages and cultures of their staff.
ODP recommends reviewing the resources under “Supporting Organizations with tools to improve diversity, equity and inclusion (DEI) performance” on https://home.myodp.org/resources/diversity-equity-inclusion/.
PERFORMANCE MEASURES: SUPPORTING INDIVIDUALS WITH COMPLEX NEEDS
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 Provider Self-Assessment: “ODP will review Supports Intensity Scale (SIS) NL and Health Risk Screening Tool (HRST) data to determine provider status 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/).
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 then 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 increasing awareness of and participation in flu vaccination, and therefore reduce number of interruptions in daily activities due to influenza in the future.
In general, elements of a plan include items such as the following:
– Clear objectives
– Defined roles
– Procedures for timelines and updates
– Protocols for decision-making
– Plans for training staff
– Outline of how data will be used
As a reminder, “clinical issues” is a discrete metric in HRST.
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 data submission tool. ODP expects that residential providers will establish these relationships to ensure individuals have access to all needed medical and mental health assessment and treatment.
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. ODP is asking for relationships that have been established by July 1, 2024, for providers that are submitting for tier assignment in August and February 15, 2025, for providers submitting in February/March 2025.
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.
For the first contract year, this measure solely requires submission of an attestation. As outlined on the attestation form, the provider is expected to produce documentation demonstrating the Residential Provider meets the requirements for all items checked upon request by ODP.
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.
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.
The following crisis prevention and de-escalation training programs meet measure CN-DD/Bx.03.3:
– 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: REFERRAL AND DISCHARGE PRACTICES
See Residential Performance Standards
PERFORMANCE MEASURES: DATA MANAGEMENT
The provider can choose to submit an operational or quality report that covers either Calendar Year 2023 or Fiscal Year 2023-24.
The requirement to have an Electronic Health Record applies to Life Sharing and Supported Living providers in the Select or Clinically Enhanced Tiers. For contract year 2025-2026, 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: RISK MANAGEMENT
Providers can access their data for RM.IM.01.2 and RM.IM.01.3, through the Enterprise Incident Management dashboard. ODP recommends reviewing Incident Reporting Overview Dashboard Training Guide for more information.
ODP will publish status by MPI for RM-IM.01.1 – 01.3 on Performance-Based Contracting – MyODP.
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 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.
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.
PERFORMANCE MEASURES: EMPLOYMENT
See Residential Performance Standards
PERFORMANCE MEASURES: USE OF REMOTE SUPPORT TECHNOLOGY
See Residential Performance Standards
PERFORMANCE MEASURES: REGULATORY COMPLIANCE
See Residential Performance Standards
PERFORMANCE MEASURES: QUALITY
See Residential Performance Standards
PERFORMANCE MEASURES: ADMINISTRATION
Providers of Residential Habilitation, Life Sharing, and/or Supported Living services are required to “annually submit to ODP the most recent financial statement” in order to remain qualified to render the service(s). For this reason, the Data Collection Tool for each tier asks “Did your agency submit financial statements to ODP within the past 12 months?” If you answer “Yes” to this question, you will be prompted to enter the date financial statements were submitted. If you answer “No” to this question, you will be prompted to enter your agency’s financial audit, if one has been completed within the past 18 months. If your agency did not have an audit completed, you must submit current financial statements (at minimum profit/loss statements and balance sheets) reflective of your most recently completed fiscal year.
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.
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.
PAY FOR PERFORMANCE PAYMENTS
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.