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Guidance: Day Service Group Size Reduction and Alternative Location Planning

The Ohio Department of Developmental Disabilities (DODD) remains dedicated to health and public safety as the department responds to coronavirus (COVID-19). 

Current information about COVID-19 suggests that older adults and people with chronic medical conditions have a higher risk of severe illness. An important step in preventing the spread of COVID-19 is to restrict large groups of people coming together and to minimize the number of people congregating in close settings.

In Ohio, more than 26,000 people with developmental disabilities receive group-based services during the day. Group sizes vary from as small as four people to more than 100 in the same location. Providers of these group-based services have been responsive to the COVID-19 emergency in Ohio, shifting the service delivery model from facility-based day settings to services within someone’s home or residential center. Providers have reduced their daily numbers served, and many have closed services.

Because of this, and to further efforts to prevent the spread of COVID-19, Dr. Amy Acton, director of the Ohio Department of Health, has issued an order to restrict group sizes to no larger than 10 people, including the staff of the provider, within buildings where the Adult Day Support and Vocational Habilitation services are provided. This order is effective at 9 PM March 24, 2020, and applies to all providers of Adult Day Support and Vocational Habilitation, regardless of waiver, local, or intermediate care facilities (ICF) funding sources.

If it is determined that it is truly in the best interest of the person’s health and safety to receive group Adult Day Support or Vocational Habilitation in these smaller settings, providers must follow all preventative and response measures outlined by the Ohio Department of Health (ODH).

The ODH order directs necessary provider personnel at Adult Day Support or Vocational Habilitation buildings be screened for COVID-19 each time they enter the facility. DODD has developed an entry screening process tool in conjunction with ODH that may be used for these purposes.

DODD appreciates that county boards of developmental disabilities and providers are already working in creative ways to reduce group sizes and continue needed supports.

Following guidance issued March 13, providers should continue to plan for this group size restriction and to communicate that plan to people who receive their services, as well as families and guardians. As detailed in the guidance, throughout the state of emergency, the rules that require day services and Vocational Habilitation to be provided in community or work settings are being relaxed to recommend those services be provided in a person’s residence.

With this guidance, those services may be provided in the location that meets the needs of people with disabilities, and in limited circumstances may be provided in groups no larger than 10 people (including staff) to prevent the community spread of COVID-19.

Although adult day services will look different during this time of emergency, DODD encourages adult day service providers to continue to be engaged and provide services in creative ways, such as providing residential supports for Ohioans with developmental disabilities. 

Additional Residential Options

To deliver needed services and support to people with developmental disabilities, residential providers may need to augment their staff, as people will not be leaving their homes to attend day services and may need additional Homemaker/Personal Care (HPC) services in their homes.

Adult Day Support and Vocational Habilitation service providers may provide HPC services in the following ways.

  • If the Adult Day Support or Vocational Habilitation service provider is already certified to deliver HPC services, the provider may submit claims for HPC services directly to DODD through the Medicaid Billing System (eMBS). 
  • If the Adult Day Support or Vocational Habilitation service provider is not already certified to deliver HPC services, the provider can still utilize its staff to deliver HPC services by using one of the following two approaches: 
    • The provider may sub-contract with a residential services provider. The residential services provider would bill DODD for the HPC services through eMBS and use the funding received to reimburse the Adult Day Support or Vocational Habilitation provider for the services rendered by their employees. 
    • The provider may apply through DODD’s Provider Services Management (PSM) system to have HPC added to their existing certification. Once the application has been submitted, the provider can utilize the “Communicate” feature within PSM to alert DODD that the application is a request to add HPC to an existing certification for an Adult Day Support or Vocational Habilitation provider. Upon receipt of the alert through the “Communicate” feature within PSM, DODD will expedite the processing of the application for HPC. The provider will be able to bill HPC through DODD’s eMBS for services rendered for any date on or after the date the application is submitted. 
    • Electronic Visit Verification (EVV) is not a barrier to providing additional needed HPC.  
  • Adult Day Support and Vocational Habilitation service providers may also become certified in an expedited process to provide Residential Respite and Participant-Directed HPC services to people in need of those services. 
  • There are and will be other creative options that are happening throughout the state. DODD staff is available to discuss potential options and to assist in developing options through DODD’s support teams, which consist of staff ready to help county boards and providers. 

Funding 

DODD understands the stress day service providers feel as they work to retain valuable direct support professional staff and transition to different forms of day services. One initial step DODD has taken to support these efforts is a commitment to immediately issue two weeks’ worth of sustainability payments for providers of Adult Day, Vocational Habilitation, Group Employment, Integrated Employment, and Non-Medical Transportation (NMT) services.

Additionally, DODD is working closely with Ohio’s county boards of developmental disabilities, the Ohio Department of Medicaid, and the Centers for Medicare and Medicaid (CMS) to establish funding mechanisms that will assist providers to maintain at least baseline operations. It is of the utmost importance that the provider community is sustained, so services can resume as quickly as possible following the state of emergency. 

Due to the added pressures for residential providers to serve additional hours that require overtime and other financial stressors, DODD issued guidance March 19 for billing concessions. The department is listening to the concerns of residential providers and is working on solutions to support them. 

Additional information will be shared as it becomes available. 

DODD Support Teams 

Please continue to exercise flexibility to ensure the health and safety of Ohioans with developmental disabilities and their families. DODD support teams are available and consist of staff ready to help county boards and providers. 

DODD has set up a dedicated web page for department communications and links to helpful resources that will advise people with disabilities, their families, service providers, direct support professionals, county boards of developmental disabilities, and the community at large. 

For specific questions about COVID-19 and additional information and resources, DODD urges you to use the Ohio Department of Health’s call center. Call 1-833-4-ASK-ODH (1-833-427-5634), or visit coronavirus.ohio.gov.