Pennsylvania DSP Training Requirements Under 55 Pa. Code Chapter 6100

If your agency serves people with an intellectual disability or autism through Pennsylvania's Office of Developmental Programs (ODP), most of your staff training calendar comes from one regulation: 55 Pa. Code Chapter 6100. Its training sections took effect February 1, 2020, and ODP keeps reminding providers about them, most recently in ODP Announcement 26-034 (March 20, 2026) and an updated orientation and annual training FAQ published July 1, 2026.

The short version: orientation on five topics before a new direct support professional (DSP) works alone with anyone, 24 hours of training every year after that, extra training for behavior supports and medication administration, and a training record for every person. Here is how each piece works and what reviewers expect to see in your files.

Who Chapter 6100 covers

Under 55 Pa. Code § 6100.2, the chapter applies to:

• Home and community-based services (HCBS) provided through Pennsylvania's 1915(c) waivers for people with an intellectual disability or autism
• State plan HCBS for people with an intellectual disability or autism
• Intellectual disability programs and services funded only by county grants (base funding)

ODP's FAQ names the funding streams in practice: the Consolidated, Community Living, Person/Family Directed Support (P/FDS) and Adult Autism waivers, base funding and targeted support management (TSM). Services funded through the vendor fiscal/employer agent (VF/EA) financial management model are excluded.

Chapter 6100 does not apply to intermediate care facilities licensed under Chapter 6600, hospitals, nursing facilities, personal care homes, assisted living residences, licensed mental health facilities, privately funded services or the Adult Community Autism Program.

If you also operate a licensed community home, Chapter 6400 adds its own training rules on top. More on that below.

The training requirements at a glance

Before working alone: orientation

Section 6100.142 requires orientation before a new staff person works alone with individuals, and within 30 days after hire or after starting to provide a service. The orientation must cover:

• Person-centered practices, community integration, individual choice and helping individuals develop and maintain relationships
• Preventing, detecting and reporting abuse, suspected abuse and alleged abuse under the Older Adults Protective Services Act, the Child Protective Services Law and the Adult Protective Services Act
• Individual rights
• Recognizing and reporting incidents
• Job-related knowledge and skills

ODP's July 2026 FAQ answers the questions agencies ask most:

• What "working alone" means. A DSP is working alone when they are not in the line of sight of other people who have completed orientation or annual training. That includes temporary staff from a staffing agency.
• When the 30-day clock starts. Either date works: 30 calendar days after hire, or 30 calendar days after the person starts providing a service. The latest compliant date is 30 days after starting to serve someone, and the new hire can't work alone until orientation is done.
• How long it takes. There is no minimum number of hours. Orientation has to cover every topic well enough that staff can do the job.
• How it's delivered. In person, live by video or self-paced all count, but job-related knowledge and skills needs an in-person component for the health and safety of the specific people served, including individual-specific training on their individual support plan (ISP) and behavior support plan (BSP).
• Who builds the job-skills piece. Your agency does. ODP lists what it must include: health care recommendations and orders (such as safe eating, positioning and transfers, skin integrity and individual emergency procedures), behavior support and crisis intervention strategies, how the person communicates, and age-related factors such as interests and stamina.
• Rehires and transfers. Orientation taken within the past 12 months that ODP developed, or that was part of the National Alliance for Direct Support Professionals (NADSP) credentialing process, can transfer to a new provider. The job-related knowledge and skills portion always has to be repeated for the people the DSP will now support.

The rule carves out two groups: dietary, housekeeping, maintenance and ancillary staff employed by a building owner when your agency doesn't own the building, and licensed health care or social service consultants who provide a service for fewer than 30 days in a 12-month period. ODP also treats adult members of a life sharing family as volunteers, so they need orientation if they will be alone with the individual.

Every year: 24 hours or 12 hours

Section 6100.143 sets two annual tiers. DSPs, life sharers who provide a service, and direct supervisors of DSPs complete 24 hours of training related to job skills and knowledge. Management, program, administrative, fiscal and support staff, along with contractors, volunteers and interns who work alone with individuals, complete 12 hours.

Both tiers must cover the same content areas:

• Person-centered practices, community integration, individual choice and relationships
• Preventing, detecting and reporting abuse under the state's protective services laws
• Individual rights
• Recognizing and reporting incidents
• Safe and appropriate use of behavior supports, for anyone who works directly with an individual
• Implementing the individual plan, for anyone who provides an HCBS or base-funding service

How the training year works

You choose the 12 months. ODP Announcement 21-034 says a training year can be the calendar year, the state fiscal year (July 1 through June 30) or any other 12-month span, and it can be the same for everyone or set per person. The catch is that you must put the start and end dates in writing, in a training plan, policy or similar document. You're compliant if all required training happens inside the training year, even if more than 12 months pass between one year's last course and the next.

ODP's FAQ adds that a new DSP can start annual training as soon as orientation is finished.

What counts toward the hours

• Time, not topics. Hours equal the time it takes to complete the training. A one-hour course counts as one hour even if it covers four topic areas.
• Any source, if it meets the rule. Staff don't have to take every course on MyODP. Providers can build their own training or use other sources, and that training doesn't need ODP approval first, but it may be reviewed during licensing inspections, provider qualification, Quality Assessment and Improvement (QA&I) reviews and other reviews.
• College courses. A passed college course counts as one hour of training per credit hour, documented the same way as any other training.
• ISP meetings don't count for provider staff. Staff need actual training on their role in carrying out each person's ISP, including your agency's implementation plan where one applies.
• Behavior supports apply to every DSP. Staff who support someone with a BSP must be trained on that plan's strategies, and DSPs who don't support anyone with a BSP still need basic competency in the appropriate use of behavior supports.

Behavior supports and restraint

Section 6100.346 adds person-specific requirements. Anyone who implements or manages the behavior support component of an individual plan must be trained in the specific techniques used. If a physical restraint may be used, that staff person must have experienced the restraint directly on themselves. Keep documentation of who was trained, when, what the training covered and who provided it.

Medication administration

Unlicensed staff can give medications only after completing a Department-approved medication administration course, including its renewal requirements (§ 6100.462 and § 6100.468). Course graduates can give oral and topical medications and eye, nose and ear drops. Two injections need more:

• Insulin injections also require a Department-approved diabetes patient education program within the past 12 months.
• Epinephrine auto-injectors also require training within the past 24 months from a health care professional licensed, certified or registered by the Department of State.

Life sharers and service locations that the Department doesn't license use a modified version of the course. The medication rules don't apply to respite or job coaching provided for fewer than 30 days in a 12-month period (§ 6100.469).

The Department's Medication Administration Training Program is managed by ODP, and ODP Announcement 24-033 spells out the ongoing checks. New students complete four medication observations within 30 days of passing the exam. To stay qualified, each person needs an annual practicum of two medication administration observations and two medication record reviews, one of each every six months. Remediation must happen within 60 days of the practicum due date, or the person repeats the whole course. Non-oral routes such as feeding tubes, inhalation treatments, enemas and subcutaneous injections need additional training from a licensed health care professional, repeated every year.

Licensed community homes: Chapter 6400 adds emergency training

Licensed community homes follow Chapter 6400, which mirrors 6100's orientation (§ 6400.51), annual training (§ 6400.52) and training records (§ 6400.50) rules. Two differences matter for your calendar:

• Program specialists are in the 24-hour group, alongside direct service workers and their direct supervisors.
• Emergency training is required under § 6400.46. Program specialists and direct service workers are trained in fire safety and evacuation before working with individuals and again every year by a fire safety expert. They need first aid training before working with individuals, along with at least one person in each vehicle transporting individuals. And within six months of hire, then every year, program specialists, direct service workers and vehicle drivers and aides are trained in first aid, Heimlich techniques and CPR by an instructor certified by a hospital or other recognized health care organization.

ODP's FAQ points to parallel orientation and annual training sections for adult training facilities (Chapter 2380), vocational facilities (Chapter 2390) and life sharing homes (Chapter 6500), so check the chapter that matches each license you hold.

Background checks sit alongside training

Chapter 6100 also requires criminal history checks for full-time and part-time staff in every position, life sharers, adult household members in life sharing homes and out-of-home overnight respite, and consultants, interns and volunteers who provide a service (§ 6100.47), under the Older Adults Protective Services Act and the Child Protective Services Law. A child abuse history certification is required under the Child Protective Services Law (§ 6100.49). Audits commonly check clearances alongside training records, so keep both current in each personnel file.

What an audit-ready training file looks like

Section 6100.141 is short, but it decides most findings. For every person trained, keep a record that shows:

• Training source, meaning who provided the training
• Content, meaning what it covered and which required topic it meets
• Dates the training happened
• Length of the training
• Copies of certificates received
• Persons attending

Then add the pieces the other rules call for:

• Your written training year, with start and end dates (ODPANN 21-034)
• Orientation completion dates that land before the person's first time working alone, and within 30 days
• Behavior support training records naming the specific techniques and, if restraint is used, documentation that the staff person experienced it (§ 6100.346)
• Medication administration records with the person trained, date, source, trainer's name and proof the course was passed (§ 6100.468), plus annual practicum dates
• MyODP transcripts for any ODP courses. ODP says staff are responsible for keeping their own transcripts and it won't send them to employers, so ask staff for a copy as courses are completed.

Keep these records for at least four years from the end of the Commonwealth's fiscal year or your own, whichever is later, and until any audit or litigation is resolved (§ 6100.54).

How TES can help

Training & eTracking Solutions offers online courses on topics that line up with Chapter 6100's required content areas, including Person Centered Planning for Direct Support Professionals, Promoting Community Integration and Inclusion for Direct Support Professionals, Supporting Individuals and Families in Making Choices, Human Rights and Recognizing Abuse, Neglect, and Exploitation, Incident Management and Principles of Behavior Change for Direct Support Professionals. TES records each completion with its date and certificate, which covers much of what § 6100.141 asks you to keep.

Two things no outside course can do for you: your agency's training on Pennsylvania's specific abuse reporting laws and your own reporting procedures, and the individual-specific training on each person's ISP and BSP. Because ODP doesn't pre-approve outside training but may review it, map each course to the 6100.143 topic it covers in your training plan. You can browse the full TES course catalog to fill the rest of your 24 hours.

This post summarizes Pennsylvania's rules and ODP guidance as published on October 12, 2026. It is not legal advice; check the current Pennsylvania Code, ODP announcements and your provider agreement for requirements specific to your agency.