​DHS COVID-19 PROVIDER GUIDANCE // ODP​

ODP Announcement 20-055: Reinstatement
of Quality Assessment & Improvement Cycle 1 Year 3 Activities

Issued: May 11, 2020 

Audience

Administrative Entities (AEs), Supports Coordination Organizations (SCOs), Supports Coordinators (SCs), All Direct Service Providers (Waiver and Base Providers), and Other Interested Parties

Purpose

This Office of Developmental Program (ODP) communication is intended to provide guidance for the FY 2020-2021 renewal period. The following topical areas will be addressed in this communication: 

1. General Guidance –Consideration for COVID-19 Pandemic
2. Person/Family Directed Support (P/FDS) and Community Living Waiver (CLW) Cap Exceptions
3. Reminder: Leap Year to Non-Leap Year
4. Variance Process for Established Service Requirements
5. Consolidated Waiver Fee Schedule Residential Rate Exception
6. Resources
   

Discussion

ODP extends our utmost appreciation and gratitude to all stakeholders who have had to adjust their work efforts because of the COVID-19 pandemic to ensure individuals’ and families’ health, safety and support needs are met. 

This communication is intended to provide guidance to all stakeholders who participate in the FY renewal Individual Support Plan (ISP) process. While ODP has not added any new services that will impact the 2020-2021 FY renewal ISP, it is anticipated that the COVID-19 pandemic will continue to influence FY 2020-2021 services. 

Please note that ODP will not be performing a one-time automated creation of 2020- 2021 FY Renewal plans. 

General Guidance

It is unknown at this time when the impacts of the COVID-19 pandemic will cease. To ensure adequate planning to meet the anticipated needs of individuals during FY 2020- 2021, all stakeholders involved in the planning process should assume, at a minimum, that an individual’s level of need will continue to be the same in FY 2020-2021. The 2020-2021 FY renewal ISP should reflect the individual’s level of need as it exists today as a result of the COVID-19 pandemic. As conditions and needs change during FY 2020- 2021, the individual’s needs should be discussed and evaluated during ISP Team meetings and the individual’s ISP should be revised to accurately reflect the individual’s needs. Teams should expect to meet, as needed, to address the impact of restrictions that were imposed as a result of the COVID-19 pandemic being lifted and changes in the individual’s supports needs as a result. Meetings may need to occur that are outside the normal annual meeting. 

Guidance to Address Shifts in Services and Service Levels Due to COVID-19 Pandemic 

ODP recognizes that the COVID-19 pandemic has caused community-based service delivery to shift to alternative approaches and supports, such as using a remote option for the provision of services. Fiscal year 2020-2021 ISPs should reflect services, utilization levels and time frames that most accurately reflect and will meet the individual’s anticipated needs. 

ISP teams should reference ODP’s Transition Guidance Toolkit and probe guidance in the annotated ISP to assess risk related to the COVID-19 pandemic and determine for each individual what services and supports are needed for the individual to be able to safely resume activities or engage in new activities. All conditions outlined in Appendix K of the Intellectual Disabilities/Autism Waivers Operational Guidance (version 1.0) continue to apply.

Guidance to Drafting FY 2020-2021 Renewal Plans 

When creating draft FY renewal ISPs, the Home and Community Services Information System (HCSIS) is designed to copy the exact information specified on the existing approved FY 2019-2020 ISP into FY 2020-2021 renewal ISP. This includes all partial year FY 2019-2020 service segments, units, and Service Start Date and Service End Date. As a result, there will be instances where because services are provided as a result of the COVID-19 pandemic, plan revisions are needed to the 2020-2021 FY Renewal service lines. In these cases, the Service Start and End Date will require adjustment to reflect the number of days found in the COVID-19 FY 2019-2020 service lines. Where services are provided as a result of the COVID-19 pandemic, the SCO and AE should ensure the ISP Service End Date reflects the same duration as the FY 2019-2020 service line. See the following chart for different Start and End Dates that may be in the FY 2019-2020 ISP and the Start and End Dates associated with the same duration for the 2020-2021 FY renewal ISP. 

Person/Family Directed Support Waiver (P/FDS) and Community Living Waiver (CLW) Cap Exceptions

ODP will not be approving any new P/FDS or CLW cap exceptions unless services, as a result of the COVID-19 pandemic, are extended beyond current expectations. Individuals approved for a P/FDS or CLW cap exception in FY 2019-2020 will continue to be exempt from the cap in FY 2020-2021 due to the COVID-19 pandemic. For individuals currently not approved for a cap exception and whose anticipated needs are expected to exceed the P/FDS or CLW cap in FY 2020-2021, due to the COVID-19 pandemic, refer to Appendix K of the Intellectual Disabilities/Autism Waivers Operational Guidance (version 1.0) and the ODP message issued via the AE Listserv on Wed 4/29/2020 at 12:19 PM. 

Due to the auto authorization functionality within HCSIS, SCs should mark ISPs for manual review for FY 2020-2021 ISPs approved for an individual cap exception. AEs will conduct manual reviews of ISPs to ensure that the approved cap is not exceeded. AEs will need to manually approve and authorize the ISPs with approved exceptions to ensure the content and services are aligned with the COVID-19 Appendix K Operational Guidance in ODP communication 20-027. AEs should identify and report to their designated ODP Regional Office any individual for whom an individual exception is no longer needed. 

It is ODP’s expectation that ongoing planning efforts to transition individuals to the CLW continue for individuals who are approved for a P/FDS cap exception prior to the COVID19 pandemic. After the FY renewal period, ODP intends to request updates from applicable parties on transition efforts. A future ODP communication will outline AE reporting requirements to support ODP assessment of transition efforts. 

Cap exception questions should be directed to your ODP Regional Program Office.

Leap Year to Non-Leap Year

Since FY 2019-2020 was a leap year with 366 days, FY 2020-2021 ISPs must be adjusted to ensure the units and dollar amounts reflect a 365-day fiscal year period versus a 366- day fiscal year period, where applicable. 

Variance Process for Established Service Requirements

• Ongoing variances for services that are not as a result of the COVID-19 pandemic should continue to be submitted based on annual dates.
• A provider should not render services and supports that are not as a result of the COVID-19 pandemic beyond the applicable waiver requirement without first receiving approval as stipulated in ODP Bulletin 00-18-06.
• Variance requests for services provided to an individual as a result of the COVID19 pandemic are not required as stipulated in the Appendix K Operational Guide.
• Variance approvals that are not as result of the COVID-19 pandemic that overlap into FY 2020-2021 (i.e. Intensive Staff Support), require a new approval when the current approval expires.
• Service, service units and service date segments on the FY renewal ISPs should accurately reflect approved units and approved variance timeframes.
• For more information regarding the Variance process and form, see ODP Bulletin 00-18-06, titled “Process to Request a Variance in Waiver Programs.” 
  

Consolidated Waiver Fee Schedule Residential Rate Exemption

ODP will carry forward all approved Needs Exception Allowances from FY 2019-2020 to FY 2020-2021. 

Resources

• For information related to special considerations, please contact the ODP Regional Program Office assigned to your region. 
  
• For questions related to the participant-directed services rate table or calculator, please e-mail the ODP, Division of Provider Assistance and Rate Setting mailbox: raratesetting@pa.gov 
• For instructions on how to perform a FY renewal ISP