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Providers will Resume Full Compliance with Rules that Apply to Hiring and Training of DSPs

During the COVID-19 Pandemic, DODD has granted certain flexibilities to certified providers and ICFs regarding the hiring and training of Direct Support Professionals (DSPs). Effective September 1, 2021, providers will be expected to resume full compliance with all rules applicable to the hiring and training of DSPs, except for flexibilities around initial training and First Aid/CPR described below.

Full compliance includes:

  • HSD/GED/rule waiver
    • DODD will temporarily waive the requirement that DSPs must have a high school diploma or GED. This waiver will be effective from September 17, 2021, through September 30, 2022. Employees without a high school diploma or GED cannot be certified to administer medications. Read more.
  • Background checks
    • Employers will be required to initiate all applicable required Background Checks (BCII, FBI, required database checks, etc.) prior to employment.
      • Rule permits an agency to preliminarily employ a DSP for up to 60 days pending receipt of the results of the BCII check, provided the applicant has signed a Criminal
        Notification/Attestation statement prior to employment. Upon receipt of the completed background check, appropriate action must be taken if any disqualifying offenses are revealed.
    • Agencies must continue to enroll persons in Rapback within 14 days of receipt of the BCII check.
      • Previously identified issues related to Rapback enrollment have been reported as resolved.
  • Initial Training
    • DODD will continue to accept condensed initial training through December 31, 2021
      • The condensed initial training must include:
        • Training to recognize and report major unusual incidents (MUIs) and unusual incidents (UIs). The training must include at a minimum the definitions of MUIs and UIs, as well as the agency's procedures for reporting.
        • Universal precautions.
        • Training provided or arranged by the agency provider specific to the individual service plan (ISP) of each person the DSP will support.
    • Initial training must always be conducted prior to the DSP providing services.
    • Resuming January 1, 2022, initial training conducted after this date will need to comply with the Agency and Independent Certification rules and/or the Administration of Licensed Facilities rule.
  • First Aid/CPR
    • Staring September 1, 2021, all DSPs must have First Aid/CPR training prior to providing services except for those employed at Facilities subject to OAC 5123:2-3-01 (F) (1)(h-i).
    • First Aid/CPR training that does not include an in-person skills assessment will continue to be accepted through December 31, 2021.
    • Training that includes an in-person skills assessment will again be required effective January 1, 2022.
    • For DSPs who obtain CPR/First Aid training that does not include an in-person skills demonstration prior to January 1, 2022, DODD will accept this as valid training through the certificate’s expiration date. Upon renewal, the DSP will be expected to obtain training that includes the required in-person skills assessment.
  • Medication Administration Certification
    • Medication Administration Certificates that were set to expire between March 9, 2020 and April 1, 2021 were extended until July 1, 2021 by House Bill 404.
    • Any certificates set to expire during that time that have not been renewed have lapsed as of July 2, 2021.
    • All DSPs administering medication must have a current Medication Administration Certificate.
  • Agencies that share DSPs:
    • If agencies share DSPs, each agency is required to maintain their own personnel record that demonstrates that agency’s compliance with personnel requirements
  • Compliance with all other applicable hiring and training requirements outlined in Ohio Administrative Code Chapter 5123.

 For additional compliance resources, visit Compliance on DODD’s website.