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Pennsylvania Releases New Rates for Service Coordinators: Appeals Deadline April 7, 2026

On Friday, March 7, 2026, Pennsylvania’s Office of Development Programs (ODP) published final fee schedule rates for supports coordination (SC) and targeted supports management (TSM) services provided under Pennsylvania’s Medicaid waiver programs to individuals with intellectual disabilities and/or autism.  The rates become effective July 1, 2026.  The rates were published as official in the Pennsylvania Bulletin on Saturday, March 8, 2026.  The Pennsylvania Bulletin notice is available online at this link.

Based on the March 8, 2026 publication date, Supports Coordination Organizations (SCOs) and other providers impacted by the new rates must file appeals with the Bureau of Hearings and Appeals (BHA) within the Department of Human Services no later than April 7, 2026.

Vorys is proud to represent numerous ID/A providers in rate appeals pending before BHA, including SCOs.  We are currently accepting new clients who wish to appeal the newly published rates.  SCOs interested in discussing how Vorys can represent their organization at no financial risk to the provider should contact one of the listed Vorys lawyers as soon as possible, to ensure compliance with the April 7 deadline.

Background

Services to the ID/A community are funded through a mixture of federal dollars and state-budget dollars through Pennsylvania’s approved Medicaid waiver(s) with the Centers for Medicaid Services (CMS).  As there is no significant private payor or third-party payor system for these services in Pennsylvania, ODP (as the state agency that oversees the waiver programs for ID/A services) acts effectively as the single payor for the industry.

Services funded through Consolidated, Community Living, and Person/Family Directed Support (P/FDS) Waivers and the Adult Autism Waiver are paid based on published fee schedule rates, which are typically updated roughly every three years.  ODP most recently updated the fee schedule rates in August 2024.  While new fee schedule rates for all ID/A services are not expected until 2027, ODP has published new fee schedule rates specific to SC and TSM services as part of ODP’s implementation of performance based contracting for SCOs.

Pennsylvania law (Title 55, Chapter 41 of the Pa. Code) provides every ID/A provider the legal right to appeal any ODP agency action impacting that provider, including the setting of fee schedule rates.  Recent decisions by Pennsylvania’s appellate courts have upheld that the provider’s right to appeal rates to BHA is a mandatory administrative remedy, making BHA rate appeals the provider’s sole avenue to challenge any aspect of the rate setting process.  While the issuance of new fee schedule rates triggers a 30-day window for every Pennsylvania ID/A provider to file an appeal, few providers (estimated at less than 10%) do so, historically.

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