Updated COVID-19 Guidance

Health Orders Rescinded

On June 2, 2021, the Adult Day Support and Vocational Habilitation Services order expired and the ICF/IID order was rescinded on April 27, 2021. Replacement orders from the Ohio Department of Health (ODH) are not anticipated regarding Adult Day Support (ADS), Vocational Habilitation (VH) services, or Intermediate Care Facilities for Individuals with Intellectual Disabilities (ICF) settings.

Though these and other ODH orders have expired, the general public should continue to follow the Interim Public Health Recommendations for Fully Vaccinated People issued by the Centers for Disease Control and Prevention (CDC).

Best Practice and Guidance

While there will no longer be any state-issued health orders in place, below is a summary of current Centers for Medicare and Medicaid Services (CMS) and CDC guidance that may apply to residential or non-residential services. The Ohio Department of Developmental Disabilities (DODD) strongly encourages providers to use the guidance documents to establish the best practices to support people in various service delivery environments.

The CDC continues to recommend facial coverings for any person who is not fully vaccinated, meaning two weeks after their second dose in a two-dose series, such as the Pfizer or Moderna vaccines, or two weeks after a single-dose vaccine, such as Johnson & Johnson’s Janssen vaccine.

Direct Support Professionals

According to the CDC, direct support professionals (DSPs) are in the same general risk category as health care personnel. DSPs are essential for the health and well-being of the people they support. Because of this, DSPs are exempt from the CDC Interim Public Health Recommendations for Fully Vaccinated People and should follow the Infection Prevention and Control Recommendations for Healthcare Personnel guidance from CDC which includes wearing facial coverings while working.

ICFs

According to the CDC guidance for Infection Prevention and Control Recommendations for Healthcare Personnel guidance, facial coverings are still required for all staff of ICFs regardless of vaccination status. Likewise, facial coverings are still required for all visitors to ICFs, according to CMS guidance QSO-21-14-ICF/IID, issued February 21, 2021 and updated (DATE).

ICFs should follow current guidance from the (CMS) to determine appropriate access to the facility and resident visitation.

Other Residential Settings

The CDC recommends that DSPs working in a person’s own home, apartment, small group homes, and smaller licensed waiver facilities should continue to use facial coverings.

Providers of these services can mandate their employees wear facial coverings and people receiving services can request to be supported by someone who wears a facial covering or is vaccinated.

People with disabilities wrote these tips for working with support staff including wearing facial coverings. The person making the request should understand that they may need to find another provider if they are unwilling or unable to fulfill their request. You may find additional providers in your area through the DODD Provider Search, ProviderGuidePlus, or by contacting your local county board for assistance.

Adult Day Support, Vocational Habilitation, and Adult Day Programs

As of June 2, 2021, there are no longer group size limitations or cohorting requirements in ADS or VH settings. Providers may choose to keep some or all the practices included in the previous order in place at their discretion. DSPs working in ADS, VH, and adult day program settings should continue to follow CDC Infection Prevention and Control Recommendations for Healthcare Personnel guidance.

The provider assurance process ended on June 2, 2021, and the Risk/Benefit Discussion Guide is no longer required but will continue to be available to help guide conversations if needed. The adult day service flexibilities, including ADS restart and STEP flexibilities and codes, will remain on the DODD website for reference until identified end dates. 

Transportation

DODD transportation providers are encouraged to follow the Ohio Public Transit Association COVID-19 Guidance for Ohio Public Transit and Human Service Transportation Agencies and CDC guidance on rideshares/carpooling.

General Questions about Vaccinations

Providers can inquire about a person or employee’s vaccination status. However, DODD continues to encourage providers not to mandate or refuse to provide services for people who are not vaccinated as outlined in Memo Monday, March 8, 2021.

Best Practice Links and Resources

Below is DODD recommended resources to help understand the changing Ohio Department of Health Orders:

Centers for Medicare and Medicaid Services

Vaccine Requirements for Long-Term Care

CMS QSO

CDC Guidance regarding Transportation

CDC Guidance regarding Adult Day Services

CDC Guidance for Group Homes

Updated ODH Mask Flyers:

Version 1 

Version 2

Regional Residential Crisis Support Plan

Purpose: To create a regional team structured to consult with the Ohio Department of Developmental Disabilities (DODD) on crisis issues that residential providers may be experiencing.  The process will be built upon collaboration between DODD, county boards of developmental disabilities, providers, and members of local teams. 

Contact information for each county can be found on the Residential Crisis Support Map.

The Regional Residential Crisis Support Plan is triggered when: 

A residential provider does not have the resources, staff, or residential capacity to provide the services necessary to ensure the health and safety of a person or people receiving services.  

The Regional Residential Crisis Support Plan operates as follows:

1. Provider > 2. County Board > 3. DODD Regional Team > 4. DODD Strike Team

Step 1: Provider Identifies Crisis Scenario and Attempts to Find Solutions

The provider shall try to use existing resources to address the need as best they can with local means within their control. This could include hiring new staff, incentivizing existing staff to return to duty, signing contracts with other residential providers for staffing “loans,” etc.

If that does not address the crisis, proceed to Step 2

Step 2: Provider Contacts County Board Provider Support Liaison for Help

After exhausting existing resources within their control, the provider should contact their county board provider support liaison for assistance. The county board liaison will make every effort to work within that county’s provider pool and community resources to coordinate with the person’s team* to address the crisis through any available means.

*This does NOT mean that a formal team meeting must be held, just that the team lead is contacted to gather relevant information and to ensure that members of the team are engaged in the development and implementation of a solution.

If that does not address the crisis, proceed to Step 3

Step 3: County Board Contacts DODD Regional Provider Resources and Support CRC for Support

If a county board is unable to use existing resources within their county’s control, the board should contact the DODD Provider Resources and Support CRC assigned to their region to explore possible solutions which may include utilizing support from resources and providers outside their county.  The DODD Provider Resources and Support CRC will report all residential crisis issues to Ann Weisent, Provider Resources and Support Manager, and will utilize all resources available within their region to attempt to address the need. This may include contacting other DODD regional support team members or other state agencies representatives for resources.  The assigned CRC will also contact provider association representatives to identify additional residential supports which may be available.

Regional Provider Resources and Support CRCs

Region 1 and 2 – Dawn Smith dawn.smith@dodd.ohio.gov  614-687-3548

Region 3 and 4 – Leigh Ann Smoot leighann.smoot@dodd.ohio.gov 513-432-6496

Region 5 and 6 – Michael Hogan michael.hogan@dodd.ohio.gov 330-360-6470

Provider Resources and Support Manager

Ann Weisent ann.weisent@dodd.ohio.gov  614-949-8792

If that does not address the crisis, proceed to Step 4

Step 4: DODD Regional Contacts DODD Strike Team for Help and Final Resolution

If the DODD regional support team organized by the Provider Resources and Supports CRCs cannot solve the problem with resources available to them, and all volunteer provider association representatives have been unable to identify additional capacity within the provider community, the DODD regional support team should elevate the crisis to Ann Weisent who will engage the DODD Strike Team.  The Strike team will consist of a group of senior leaders at DODD who will work to take extraordinary measures using all departmental resources to attempt to solve the crisis.

Health and Safety

DODD encourages providers to ensure that people with developmental disabilities and DSPs are familiar with and follow recommendations from the Centers for Disease Control and Prevention (CDC) and the Ohio Department of Health (ODH) related to social distancing and personal hygiene.

Following these guidelines for social distancing, providers may limit the delivery of services in community settings when appropriate.

Providers may not discharge a person from services only due to the diagnosis of COVID-19. It is expected that the provider will follow appropriate procedures as recommended by the CDC, ODH, their local health department, or health care professionals.

Providers are encouraged to ensure that a person-centered approach to services is maintained by communicating with people receiving services, their families, guardians, and DSPs to keep them updated on how they can stay safe during this state of emergency.

DSPs should be familiar with their agency’s emergency response plan.

DODD supports a provider’s ability to prioritize medical appointments, follow-ups, and consultations based on the needs of the person and after consultation with the appropriate medical professional. When possible, telehealth options, such as 24/7 nurse phone lines, should be explored.

Independent providers should be aware of each person they serve who is the designated backup provider. Providers with questions should contact the person’s service and support administrator (SSA) for details.

Billing Overview

To ensure service authorization and billing requirements are not undue barriers to service delivery and provider reimbursement throughout the coronavirus (COVID-19) state of emergency, the Ohio Department of Developmental Disabilities (DODD) is making the following changes to its processes for services delivered on or after March 12, 2020: 

• Services authorized through electronic means (by telephone, email, etc.) will be reimbursed without being reflected in DODD’s Payment Authorization for Waiver Services (PAWS) system. County board of developmental disabilities should document the authorization locally through TCM case notes when possible, or by any other means available.

• An approved prior authorization (PA) will not be required for services that exceed the Ohio Developmental Disabilities Profile (ODDP) funding range for people enrolled in the Individual Options (IO) Waiver.

• DODD’s Medicaid Services System (MSS) will not prevent the submission of claims that exceed the three percent (3%) limitation within the Monthly Rate Calculator (MRC).

• Homemaker/Personal Care (HPC) services will be permitted to be delivered and reimbursed on the same day as Ohio Shared Living if needed and authorized by the individual service plan (ISP) team. 

• Services for Level One Waiver enrollees will be reimbursed up to the total available funding within the waiver, which includes the current amount available for non-adult day array services ($6,750), plus the amounts currently available for adult day array services and Non-Medical Transportation.  

• The $8,520 Emergency Services Benefit for the Level One Waiver will continue to be available, in addition to the funding reference in the previous bullet. 

• The individual cost caps for the Self-Empowered Life Funding (SELF) Waiver are not being changed, but if enrollees require services that exceed the established cost caps for children or adults, county boards are being asked to identify ways to meet the specific needs. 

Please direct any questions regarding reimbursement for services to the DODD Support Hotline at 1-800-617-6733, option 2. 

It is likely that the expanded need for services in smaller groups and residential settings will increase the cost of waiver services during the state of emergency. DODD acknowledges that the financial commitment to support the required state matching funds obligation for waiver services is shared between the department and county boards. As such, expenditures during this period will be closely monitored, and DODD will fully honor its financial partnership with county boards. As more information becomes available regarding the specific details of the various emergency funds that might be utilized to support services, DODD will collaborate with county boards about how to best access and allocate any available funding.

Certification Spans

With the impact of the COVID-19 state of emergency, the Ohio Department of Developmental Disabilities (DODD) issued  automatic 90-day certification extensions to all providers expiring in March, April, and May 2020.

For example, a provider’s certification was set to expire April 5, 2020, was automatically extended, and the provider received a new expiration date of July 5, 2020.

This allowed providers time to focus on providing services to people with developmental disabilities and delay the need for submitting a renewal application. DODD will continue to monitor the situation during this time of emergency.

Behavioral Supports, Including Rights Restrictions

If under prior DODD guidance, plans with behavioral support strategies were implemented without human rights committee (HRC) review and approval, each county board of DD and ICF should develop a process to begin reviewing these plans and seeking HRC approval when necessary. DODD understands that county boards of DD and ICFs may have suspended restrictive measures notification (RMN) entries during the emergency. We expect county boards of DD and ICFs to begin implementing the process to accomplish all these activities now. However, the department also realizes that it will take some time to put everything in place. All plans should meet the requirements of the behavioral support rule by January 31, 2021. HRC meetings may be held virtually.

ICF Guidance

Facial coverings are still required for all staff of ICFs regardless of vaccination status according to the CDC guidance for Infection Prevention and Control Recommendations for Healthcare Personnel guidance. Likewise, facial coverings are still required for all visitors to ICFs, according to  CMS guidance QSO-21-14-ICF/IID, issued February 21, 2021.

ICFs should follow current guidance from the (CMS) to determine appropriate access to the facility and resident visitation.

Visitation in Waiver Settings

When people with developmental disabilities express an interest in resuming social visits in their homes, their support teams and roommates should have conversations about the appropriateness of visits at this time. Teams and roommates need to determine when and how to plan for visits inside and outside of the home safely and responsibly.

Teams should assist in making visits as safe as possible by working with the person and other members of the household to follow the public health guidelines, including, but not limited to

• educating all residents on the risks of the spread of COVID-19 and appropriate/applicable safety precautions to take when interacting with visitors,

• educating all families/friends of the dangers of the spread of COVID-19 and the potential health impact for not just their loved one, but all residents and staff at the home,

• educating all residents on the importance of face coverings and maintaining social distancing from people they do not currently live with when out of the home,

• encouraging DSPs and visitors coming into the person’s home to always wear a face covering,

• continuing frequent cleaning and sanitation of high touch surfaces and shared bathrooms, at least several times per day,

• continuing to encourage the utilization of technology to keep in touch with families and friends,

• and evaluating whether outdoor visitation would be more appropriate for members of the home.

Direct Support Professional Onboarding and Training

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
  • Employers will be expected to have evidence of a High School Diploma/GED OR rule waiver from the Department prior to hiring the applicant. Information about requesting HSD/GED rule waivers can be found here.
• 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.

Independent Providers

Ohioans with developmental disabilities and their families depend on independent providers to deliver personalized care, which they require to remain healthy and safe. Due to the increased need for independent providers in Ohio’s support system for people with developmental disabilities, the Ohio Department of Developmental Disabilities (DODD) is providing the following assistance to encourage more independent providers to be certified and start providing critical services during the state of emergency. The DODD website offers details about how to become an independent provider. In addition to the information on the website, DODD is providing the assistance detailed below.

Fee Waiver

The Ohio Department of Developmental Disabilities (DODD) is waiving the application fee for all initial applications for independent providers received between June 14, 2021, and September 30, 2021. The application must be completed by September 30, 2021, to receive the fee waiver.

Process Update

DODD is initiating a process for people with developmental disabilities and families who have already selected a potential provider. We will be using the below process for submitted applications to expedite the applicant who has someone waiting to receive services. An application is considered complete once all required documentation and background checks are received.

If there is an independent provider applicant chosen by a person with disabilities, guardian, or family member and the application needs expedited, please contact the provider certification department at provider.certification@dodd.ohio.gov. Please include in the body of the email the person's county board SSA contact information, the potential provider's name, email, application number, and email contacts for the person, guardian, or family members.

Positive COVID-19 Diagnosis 

Independent providers are encouraged to maintain a person-centered approach to services. Communication is critical during a state of emergency. Ensure that there is consistent communication among independent providers, the person receiving services, the person’s service, and support administrator (SSA), as well as with families or guardians.  

DODD supports independent providers’ abilities to prioritize medical appointments, follow-ups, and consultations based on the needs of the person and any advice from appropriate medical professionals. Independent providers are encouraged to utilize telehealth options when available. 

To maintain the health and safety of people receiving supports, independent providers should be aware of who is the designated backup provider for each person they support. If there is any question, providers should reach out to the person’s SSA for details.  

Exceeding 60 Hours for Services 

During this state of emergency, independent providers are enabled to exceed the 60-hour ceiling for providing services, if necessary, to maintain the health and safety of people receiving supports. Independent providers will still require authorization from the SSA. Independent providers may be authorized to deliver overtime hours through verbal or electronic authorization from the County Board prior to individual service plan (ISP) updates. Payment authorization for waiver services (PAWS) updates may be needed to reflect additional units for payment.

Training and Service Changes 

Electronic Visit Verification (EVV) training requirements are not being collected as part of the certification application at this time. The applicant may upload a blank page to that part of the independent provider application.

First Aid and CPR online-only classes are being accepted, with in-person requirements to resume in the future.

When entering Supplier ID on the application, be aware that the Supplier ID number and the Registration number from Ohio Shared Services for an account are very similar. Supplier ID numbers can be obtained here.

Even with the lenient training requirements described above,  medication administration training requirements have not changed. All independent providers who are responsible for administering medication must have medication administration training.

Alternative Service Delivery Methods 

For independent providers who are currently certified but not engaged in the delivery of services, or who may only be providing services on a part-time basis, there are many opportunities available to meet this high demand for service.

• Notify the local county board of developmental disabilities (CBDD) of the willingness to assist more people.
• Contract with an agency provider for services.
• Be hired as an employee of an agency provider.

If you are an independent provider with current, active certification, you may be hired by an agency provider without undergoing some of the traditional hiring requirements.

Agency providers hiring independent providers for direct services may forgo obtaining a BCII check if the independent provider is currently certified by DODD. Additionally, the agency can assume initial training requirements have been met as part of the independent provider certification process but must provide the independent provider with major unusual incidents (MUIs) and unusual incidents (UIs) training specific to the agency. BCII checks and enrollment in RAPBACK must be obtained if the agency maintains the independent provider in a direct support position for more than 90 days.

In addition to MUI training, the agency must provide person-specific training and in a licensed facility emergency response training for the locations in which the independent provider will be working. The condensed training referenced in the Resources for Onboarding DSPs guidance is acceptable.

With the uncertainty that many people with developmental disabilities and their families are facing, some independent providers may not be providing services to every person who they usually do provide services. If you are an independent provider and looking for more work, reach out to your local county board of developmental disabilities or local agency providers. Many people will be requiring more supports during this state of emergency, and agency providers will be looking for additional DSPs. Working for an agency may be a good way to supplement any income that may be lost during this state of emergency. 

Filing for unemployment may be an option for independent providers. The unemployment guidelines have changed due to the state of emergency.  

DODD recognizes that the following situational actions may seem excessive or unattainable due to the lack of personal protective equipment (PPE), residential space, the number of direct support professionals (DSP) or residential waiver settings that do not serve elderly or medically compromised people.

However, the following is intended to serve as a guide and is highly recommended to protect the people who the department serves and those caring for them.

All DSPs entering the residential waiver setting should be screened for symptoms using the Entry Screening Process for Prevention of COVID-19 Transmission tool. Staff performing health check screenings should wear facemasks.

DSPs with symptoms or with temperatures greater than 100 degrees Fahrenheit should be sent home. DSPs who develop symptoms or fever while in the residential waiver setting should immediately go home (not to the urgent care or emergency room unless severely ill). 

Advise people who screen positive to contact their primary care physician by phone or telehealth. The HCP will determine whether the person needs to be evaluated in person and will make a referral for evaluation and treatment, as necessary.  

A county board of developmental disabilities may approve an extension during this time, as appropriate for the person, and begin discharge planning again once the state of emergency has concluded. 

Ohio Public Health Advisory System

LTSS Pre-Surge Planning Toolkit

Electronic Visit Verification

Providers who are employing a high volume of new staff or new clients are reminded that Electronic Visit Verification (EVV) visit logging requirements remain in effect. The Ohio Department of Medicaid (ODM) is monitoring EVV visits as part of a larger strategy to identify people at risk during the state of emergency who may not be receiving the support they require to stay healthy and safe. However, it is understood that no available EVV device and other barriers may exist when logging a visit during service delivery. Please keep in mind that any visit that is not recorded in real-time can be entered manually online at a later point. EVV is not used to deny claims payment at this time.

Please note the certification requirement for EVV training is being waived at this time for new providers and existing providers adding Homemaker/Personal Care (HPC) services during the state of emergency. Providers who have not completed training will not be able to access EVV data and log visits. Because EVV is not used to deny claims payment at this time, this will have no impact on reimbursement for services provided.

Providers who wish to continue delivering HPC services after the state of emergency will be required to take EVV training and begin logging visits at a later date.

While ODM and its partner agencies suspended the requirement that new providers complete EVV training before getting a Medicaid ID during the COVID-19 pandemic, the Cures Act still requires providers to use EVV. Core training requirements must be completed before a provider can use the EVV system. For agency providers, core training requirements are the System Overview and Security modules. Non-agency providers must complete the System Overview.

• Providers new to Medicaid or who are just starting to provide services subject to EVV must complete core training as soon as possible after receiving their Medicaid provider number. After they complete core training, they will receive a link to their welcome kits by email and can begin to log visits. Information on EVV training is located on ODM’s website https://medicaid.ohio.gov/INITIATIVES/Electronic-Visit-Verification/TrainingProviders who wish to continue delivering HPC services after the state of emergency has subsided will be required to take EVV training and begin logging visits at a later date.

Adult Day Guidance

As more Ohioans with developmental disabilities are receiving COVID-19 vaccines, they are looking to safely return to the places, jobs, and activities they love. People should engage in the activities they choose and services they need in the safest way possible.

The process always begins with the person’s choice of services and is bolstered by a team discussion of the risk and benefits of that decision. To help with this discussion, reference the Risk/Benefit Discussion Guide.

DODD encourages providers to use the best practices to support a person’s choice to safely receive services.

DODD also encourages providers to explore alternative service delivery methods, such as the use of Remote Support or allowing people to receive services in the homes of DSPs. People receiving services, guardians, and teams must be consulted and approve these alternatives.

It is recommended that staffing ratios be maintained whenever possible, but when not possible, the provider should ensure that the SSA is aware and be prepared to discuss ways in which the provider can continue to ensure the health and safety of the person.

Adult Day Service Best Practices

As of June 2, 2021, there are no longer group size limitations or cohort requirements in ADS or VH settings. Providers may choose to keep some or all the practices included in the previous order in place at their discretion. DSPs working in ADS, VH, and adult day program settings should continue to follow CDC Infection Prevention and Control Recommendations for Healthcare Personnel guidance.

The provider assurance process ended on June 2, 2021, and the Risk/Benefit Discussion Guide is no longer required but will continue to be available to help guide conversations if needed. The adult day service flexibilities, including ADS restart and STEP flexibilities and codes, will remain with the details listed below.

Adult Day Service Flexibilities

Current flexibilities that exist for providers:

• ADS/VH can be provided in a person’s home, virtually, or on behalf of when determined appropriate through the person-centered planning process.
• Personnel flexibility

• • ADS/VH providers may provide Homemaker/Personal Care (HPC) and Residential Respite.

• • • Subcontracting with residential providers; or,
    • Expediting adding these services to their provider certification.

• • Onboarding training of DSPs.
  • Sharing of DSPs across agencies.
  • Subcontracting with DSPs certified as independent providers of HPC.

Adult Day Service Restart 

DODD will resume using the ADS/VH rates associated with the acuity group assignment for each person receiving services effective September 1, 2021. Providers may continue to use the Restart billing codes for ADS/VH services delivered on or before August 31, 2021.  For services delivered on or after September 1, 2021, providers should use the traditional ADS/VH billing codes. 

It is not necessary for individual services plans (ISPs) and Payment Authorizations for Waiver Services (PAWS) to be updated prior to September 1, 2021, for providers to be properly reimbursed.  ADS and VH services are represented on the PAWS by roll-up codes rather than by distinct billing codes, therefore, as long as ADS and/or VH services are authorized in the ISP, the billing system will look for the associated roll-up code on the PAWS to properly process claims. 

STEP Billing Code

During the COVID-19 pandemic, via Appendix K, DODD was able to approve the adult day support (ADS) and vocational habilitation (VH) service to be provided in modified ways to ensure essential adult day and employment services were available in smaller groups and alternative settings. Appendix K allowed DODD to approve adult day support and vocational habilitation service to be provided in someone’s home, virtually, or on behalf of. These are in conjunction with these services already being able to be provided in a developmental disability-specific facility or community setting. Currently, Appendix K has been authorized until January 21, 2022.

STEP Specifics Effective January 1, 2021

• Providing ADS and/or VH in a group of no larger than five people, not including a DSP.

• Providing ADS and/or VH in someone’s home, virtually, on behalf of, in the community, or a combination of these ways. 

• • Services should not be delivered in a facility-based ADS or VH site, except for when a drop-in is needed. A provider delivering ADS and/or VH in this way may drop into a congregate setting. Groups must remain separated from ADS/VH cohorts within the congregate setting. People may remain within the congregate setting the amount of time necessary to address individual needs.

STEP Billing Rates and Codes

To support ADS and VH being provided in alternative ways, DODD created a billing code for providers to use when offering STEP services.

• The STEP billing code reimbursement rate is based on the service rates for Acuity Group C.

• Services can be billed in 15 minutes or at a daily rate. Please see ADS and/or VH rules regarding daily billing requirements.

• County boards do not need to request an administrative budget override for each person who utilizes ADS/VH STEP. DODD’s billing system will recognize that these billing codes are to be paid at the rates established for Acuity Group C.

• If a person meets the established criteria, the provider may also bill for the Medical Add-On and/or Behavioral Add-On as appropriate.

As a rule, routine Homemaker/Personal Care (HPC), Shared Living, and ADS are not permitted to be billed concurrently. Any potential for overlaps between HPC or Shared Living services and this modified adult day service option will need to be carefully considered on a case-by-case basis and only authorized when supported by a documented need.

Providers who are interested in delivering ADS/VH in these alternative ways should contact the local county board to discuss which people might need and benefit from ADS or VH services delivered in this fashion.

The chart below includes the STEP billing codes and PAWS Roll-up codes which include both 15-minute unit codes and the new day unit codes.

HPC Options for ADS Providers

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 subcontract 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. 

• 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. 

• Providers may explore the availability of an alternative workforce, such as college students or people without high school diplomas or GEDs, as well as the possibility of working with local county boards of developmental disabilities to identify other potential groups of people in local communities. The staff person may be placed in a direct support position immediately. Providers must ensure that newly hired or reassigned DSPs have condensed training to recognize and report major unusual incidents (MUIs) and unusual incidents (UIs), as well as universal precautions. The training must include, at minimum, the definitions of MUIs and UIs and the agency’s procedures for reporting. 

• If provider agencies need to share DSPs, a statement can be accepted from a DSP’s primary employer stating that the DSP has required training and background checks for them to work for a different agency. These employees must still receive person-specific training (including crisis intervention, if necessary) and site emergency response training. A provider who chooses to utilize non-traditional DSPs in direct support positions must initiate appropriate background checks, driver’s abstract (if driving), and the required registry checks, but may place the staff person on the schedule immediately. Online CPR/first aid classes will be accepted until further notice. CPR/first aid certification as required by rule must be obtained if the staff person maintains a direct support position beyond the state of emergency. DSPs without current CPR/first aid may provide direct supports if the DSP is working with a nurse or at least one other DSP who has current CPR/first aid certification. 

• Even with the lenient training requirements described above,  medication administration training requirements have not changed. All independent providers and DSPs who are responsible for administering medication must have medication administration training. Providers whose certifications are expired for no more than 180 days may continue to administer medications and get renewal of certifications during that extension.  

• If provider agencies need to share DSPs, a statement can be accepted from a DSP’s primary employer stating that the DSP has the required training and background checks for them to work for a different agency. These employees must still receive person-specific training (including crisis intervention, if necessary) and site emergency response training. Additionally, HPC services may be provided by the utilization of DSPs currently employed by Adult Day Array provider agencies.

• If the Adult Day Array 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.

• If the Adult Day Array service provider is not already certified to deliver HPC services, the provider may enter into a sub-contractual arrangement with the residential services provider. The residential services provider would bill for the HPC services to DODD through the Medicaid Billing System and use the funding received to reimburse the Adult Day Services 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.

Transportation

DODD transportation providers are encouraged to follow the Ohio Public Transit Association COVID-19 Guidance for Ohio Public Transit and Human Service Transportation Agencies and CDC guidance on rideshares/carpooling.

Respite

DODD recognizes that many places, including residential waiver settings and ICFs, provide much-needed respite services. During this time, providers should cancel all non-emergency respite stays. If a residential waiver setting is contacted to provide respite services, they must first contact the person’s local county board of developmental disabilities to discuss the need for the respite service.

If it is determined that the need is of an emergency nature, the provider may provide respite services to the person following the initial screening of the person.

To continue to support people being safe and staying in their current locations, the Ohio Department of Developmental Disabilities has received approval to temporarily lift the maximum days allowed for Residential Respite services identified in the waiver rules for a person during their waiver span. 

If, by having a person using respite in the facility, the facility is caused to go over capacity, the facility must still submit a request for a waiver of licensed capacity. Those requests will be reviewed and responded to as quickly as possible.

Cares Act Provider Relief Fund

The CARES Act created a Provider Relief Fund to distribute federal funds to providers in response to COVID-19. The U.S. Department of Health and Human Services (HHS) expects to distribute $15 billion to eligible Medicaid and Children’s Health Insurance Program (CHIP) providers.

All Ohio providers are eligible to apply for relief funds through the provider relief portal. This portal allows providers to attest to relief fund payments made for healthcare-related expenses or lost revenue attributable to COVID-19.

Before applying through the provider relief portal, The Ohio Department of Developmental Disabilities strongly encourages applicants to read the Medicaid Provider Distribution Instructions and download and complete the Medicaid Provider Distribution Application Form.

Questions? Support is available by contacting HHS at (866) 569-3522.

Resources

Plain Language Doc - COVID-19

Vaccine Provider Best Practices

Getting a Vaccine: What to Know About Me

Getting a Vaccine: What to Expect

Plain Language: Ohio’s COVID-19 Vaccination Program

Social Story: Getting a COVID-19 Vaccine (From UC UCEDD and the Center for Dignity in Healthcare for People with Disabilities)

Monoclonal Antibodies Treatment for COVID-19

DODD-ODH Recorded Infection Control Webinar

Guidance – Health and Safety Supplies

What COVID-19 Means for DSPs 

What COVID-19 Means for Families

LTSS Toolkit

DODD Support Teams

COVID-19 Resources: Non-Guidance

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