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Guidance: Providers of Waiver-Funded Services

This guidance was updated on July 24, 2020. The highlighted portion reflects updated information.

Attention Providers of Waiver-Funded Services:

As the Ohio Department of Developmental Disabilities (DODD) responds to coronavirus (COVID-19), please continue to exercise flexibility to ensure the health and safety of Ohioans with developmental disabilities and their families. DODD appreciates the unique role that providers of service and direct support professionals (DSPs) play throughout the developmental disabilities system.

As of the close of business March 13, DODD’s Office of System Support and Standards (OSSAS) suspended regularly scheduled compliance reviews and regulatory work [Plan of Correction (POC) and Plan of Correction - Verification (POC-V)] in response to COVID-19.

The following information gives recommendations and guidance on important issues for waiver-funded service providers and is effective immediately.

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 is encouraging each provider to develop visitation practices that include, at a minimum, limiting visitors, creating a screening process for visitors, and using sign-in sheets to track visitors. A provider may lock doors to limit entry into the building but must still ensure there are at least two means of egress from each floor of the building.

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 for each person they serve who is the designated back-up provider. Providers with questions should contact the person’s service and support administrator (SSA) for details.

Direct Support Professional Training

Updated April 13*

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. Applicants under 18 years of age must have a rule waiver approved by the department prior to hiring these applicants.

Agency providers hiring currently certified 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 must be obtained if the agency maintains the independent provider in a direct support position after July 31, 2020.

In addition to MUI training, the agency must provide person-specific training and 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.

Providers must ensure that newly hired or reassigned staff have condensed training to recognize and report MUIs and 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 staff, a statement can be accepted from a DSP’s primary employer stating they have the required training and background checks in order for them to work for a different agency.  Effective 9/1/2020, agencies who employ a DSP based on a statement from the primary employer must initiate their own BCII check and complete the required database checks within 10 days of hire.  Agencies who hired shared DSPs prior to 9/1/2020 must request a BCII check and complete the database checks by 9/10/2020.

A provider who chooses to utilize non-traditional staff 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. RAPBACK is not required unless the staff person maintains a direct support position after June 1, 2020.

Online CPR/first aid classes will be accepted. Appropriate CPR/first aid certification must be obtained if the staff person maintains a direct support position after June 1, 2020.

Staff without current CPR/first aid may provide direct supports as long as they are working with a nurse or at least one other staff person who has current CPR/first aid certification.

Even with the lenient training requirements described above, the medication administration training requirements have not changed. All staff 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. (Note: This requirement was updated March 18, 2020.)

Providers are encouraged to work with families to explore the availability of natural supports, if needed.

Providers are encouraged to utilize all staff in the provision of direct support. This includes management and clerical staff, as examples. The training expectations for this staff is the same as described in this section.

Electronic Visit Verification

Updated March 30, 2020*

Providers who are employing a high volume of new staff and/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.

Service Delivery

Review DODD’s guidance about Day Support Service Options for new options effective for partnerships between adult day and residential service providers.

DODD 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 direct support professionals. 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.

Licensed residential facilities may operate over their licensed capacity with team approval when bedrooms need to be shared. A rule waiver should be requested and will be granted expeditiously by DODD.

DODD Support Teams

In this critical time, everyone will be required to work collaboratively, operate differently, and be proactive to limit the spread of COVID-19. During this state of emergency, DODD fully realizes there are on-the-ground issues that require flexibility from normal operations and additional assistance from the department.

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.