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DHS COVID-19 PROVIDER GUIDANCE // ODP

ODP Announcement 20-101 Update: Temporary Closure of Older Adult Daily Living Centers, Structured Day Habilitation, and Licensed Facilities Where Community Participation Support is Provided Due to Community Spread and When Staff or Individuals Are Diagnosed with COVID-19, and the Process for Re-opening Facilities

Update: December 10, 2020; Issued: October 9, 2020 

Audience

    • Providers of Facility-Based Community Participation Supports (CPS)
    • Operators of Adult Training Facilities licensed under 55 Pa. Code Chapter 2380
    • Operators of Vocational Facilities licensed under 55 Pa. Code Chapter 2390
    • Operators of Older Adult Daily Living Centers licensed under 6 Pa. Code Chapter 11
    • Providers of Facility-Based Day Habilitation in the Adult Autism Waiver
    • Providers of Adult Daily Living Services
    • Supports Coordination Organizations (SCOs)
    • Service Coordination (SC) Entities
    • Community Health Choices Managed Care Organizations (CHC-MCOs)
    • Living Independence for the Elderly (LIFE) Provider Organizations
    • Administrative Entities (AEs)
    • Area Agencies on Aging (AAAs)
    • Other interested parties

Purpose

To provide temporary closure guidance to Older Adult Daily Living Centers, Structured Day Programs, LIFE Day Centers, Adult Training Facilities and Vocational Facilities related to the community spread of COVID-19 or when an individual or staff member is diagnosed with COVID-19 and spent 15 minutes or more in the facility within a 24 hour period starting from 2 days before illness onset (or, for asymptomatic patients, 2 days prior to test specimen collection) until the time the person is isolated. Additionally, this announcement describes the process for re-opening facilities using the Community Participation Support and Older Adult Facility Reopening Tool.

Discussion

The Department of Human Services (DHS) and the Pennsylvania Department of Aging (PDA) are working together to provide stakeholders with guidance on the community spread of COVID-19 and recommendations on when the settings listed under the purpose section should close. This guidance is intended to build on COVID-19 mitigation strategies within the service delivery system. 

I. Thresholds for Community Spread

Community Transmission 

For the purposes of this communication, ”community transmission” is measured by a key indicator tracked and reported by the Department of Health (DOH), the polymerase chain reaction (PCR) Percent Positivity rate; which is the percentage of people that test positive for COVID-19 out of the total of everyone that is tested for COVID-19 within a county. The PCR percent positivity provides the threshold for the three levels of community transmission by county (low, moderate, substantial). Older Adult Daily Living Centers, Structured Day Programs, LIFE Day Centers, Adult Training Facilities and Vocational Facilities can use the following chart to guide decision making on further modifying operations or temporary closure if the county in which they are located is found to meet the Moderate or Substantial threshold for community spread.

Thresholds for Community Spread​
​Level of Community Transmission
in the County
​PCR Percent Positivity
(Most Recent 7 Days)
​Recommended Facility Operational Status
​Low
​Less than 5 percent
​Remain open or re-open if previously closed and Low threshold met continuously over a 14-day period
​Moderate
​5-10 percent
​Facilities may choose to close, stay closed, remain open, or reopen if previously closed. If a facility remains open or reopens while the level of community transmission is moderate, it is recommended that the facility increase mitigation measures related to COVID-19 including, but not limited to: (1) inform participants with high risk needs of the “moderate” level of community transmission designation; (2) consider reduction in the number of service days to provide for additional cleaning; (3) reduce, or at a minimum, not expand current capacity; (4) make alternative transportation plans for anyone using public transit or multi-passenger vehicles with passengers from multiple locations.
​Substantial
​more than 10 percent
​Close or remain closed until the level of community transmission returns to and remains in low or moderate for 14 days.

Example of Timeline for Re-Opening

​Friday, November 6th;  County Community Spready Level — Substantial
Monday, November 9th​​Facility closes for 7 days while level of spread is substantial
​Friday, November 13th; County Community Spread Level — Low or Moderate
​November 14-20
​Facility remains closed until level of spread is moderate or low for 14 days (post substantial)
​Friday, November 20th; County Community Spread Level — Low to Moderate
​November 21-27
​Facility remains closed until level of spread is moderate or low for 14 days
​ ​Friday, November 27; County Community Spread Level — Low or Moderate
​November 28
​Facility Opens

Should a facility remain open or re-open, it is recommended that the provider review the health risks of the individuals the provider serves and the behavioral risks (e.g. ability to tolerate masks, hand hygiene, social distancing) of COVID-19 transmission for the individuals the provider serves. Providers should review the COVID-19 mitigation strategies used during transportation and service provision to determine whether additional COVID-19 mitigation strategies need to be implemented as result of an increase in community transmission in the county where the provider operates. Providers should develop plans to protect the health and safety of their staff and the individuals they serve, as well as the families of staff and of the individuals served, that include the following:

      • Changes to the method of service delivery and how staff will be deployed (e.g., remote versus in-person, in-home versus in congregate settings);
      • Enhancements to existing or implementation of additional COVID-19 mitigation strategies in alignment with applicable COVID-19 guidance; and
      • Communication of changes the provider has made to individuals, families, Supports Coordinators, and any other affected providers.


Notification

Utilizing the information published by DOH in the COVID-19 Early Warning Monitoring System Dashboard; PDA, Office of Long-Term Living (OLTL), and Office of Developmental Programs (ODP) will jointly publish a weekly Thresholds for Community Spread Report that identifies the Level of Community Transmission in the County (i.e. low, moderate, substantial). Providers will be responsible to review the report weekly and make any necessary changes according to the status of their county. The publication of the Threshold for Community Spread Report will follow publication of DOH’s updated Dashboard numbers, which is available on Friday of each week. A provider is expected to implement recommended operational status by the following Monday.

​PDA
​Will send weekly Thresholds for Community Spread Report directly to providers
​OLTL
​ Will send weekly Thresholds for Community Spread Report directly to providers, SCs and CHC-MCOs
​ODP
​Will send weekly Thresholds for Community Spread Report to Administrative Entities (AEs), SCOs and Providers via ODP listservs.

Provider Engagement Tracking

​PDA
  • ​Providers of Older Adult Daily Living Services will notify the Department of center closures and re-openings. The notification shall be made orally within 24 hours, and written report submitted within 3 working days.
  • PDA will track center closure dates and re-opening dates internally.
​OLTL
  • ​LIFE Provider Organizations will notify OLTL of center closures and re-openings. The notification shall be made orally within 24 hours, and written report submitted within 3 working days.
  • Providers of Adult Daily Living Services will notify the participant’s SC or CHCMCO of any closures and projected re-opening dates. The notification shall be made orally within 24 hours, and written report submitted within 3 working days.
  • The SC or CHC-MCO will track closures and projected re-opening dates to ensure coordination of services for participants.
  • Providers of Adult Daily Living Services in the CHC or OBRA Waiver should notify the participant’s SC or CHC-MCO of any re-opening plans. 
​ODP
  • ​CPS providers will notify ODP/AEs by completing a site level incident report in EIM within 24 hours of the closure, in accord with the incident management bulletin

Additional Considerations 

The guidance is not intended to override a county or local jurisdiction that may have more strict standards.

II. Temporary Closure of Older Adult Daily Living Centers, Structured Day Habilitation, and Licensed Facilities Where Community Participation Support is Provided When Staff or Individuals Are Diagnosed with COVID-19

Recommendations for Closure 

To mitigate the spread of COVID-19 in Older Adult Daily Living Centers, Structured Day Programs, Adult Training Facilities and Vocational Facilities, temporary program closure is recommended in the following situations:

Situation
​Temporary Closure Guidance1
​Staff who rendered services or an individual who receives services:
    1. Tested positive for COVID-19
    2. Is asymptomatic
    3. Does not know the date of exposure to COVID-19.
​The setting should close if the staff or individual was present in the setting at any point starting 48 hours before the test date.
​Staff who rendered services or an individual who receives services:
    1. Tested positive for COVID-19
    2. Is asymptomatic
    3. Knows the date of exposure to COVID19.
​The setting should close if the staff or individual was present in the setting at any point starting 48 hours after the diagnosed person was exposed to COVID-19.
​Staff who rendered services or an individual who received services:
    1. Exhibits symptoms of COVID-192 
    2. Subsequently tested positive for COVID-19.
​The setting should close if the staff or individual was present in the setting at any point starting 48 hours prior to the time the person started exhibiting symptoms of COVID-19.


Closure Guidance

      • The provider closes the setting for 14 calendar days starting from the date that the provider was notified of the COVID-19 diagnosis.
      • If a provider received guidance from the Department of Health or the local Department of Health that the licensed setting can re-open in less than 14 days, the provider may choose to do so, but must still follow the re-opening guidance.
      • The provider should encourage individuals and staff who were present in the setting within a 24 hour period starting from 2 days before illness onset (or, for asymptomatic patients, 2 days prior to test specimen collection) until the time the person is isolated to quarantine at home for 14 days.
      • Back-up plans to ensure the health and welfare of all individuals impacted by the closure of the setting must be implemented.

Notification of closure activities must be provided to the parties listed below:

Setting
Notify
​Facility-Based Community Participation Support
  • ​Individuals who receive services in the facility
  • Supports Coordinators of individuals who receive services in the facility
  • Administrative Entity
  • ODP Regional Office
​Facility-Based Day Habilitation
(Adult Autism Waiver)
  • ​Individuals who receive services in the facility
  • Supports Coordinators of individuals who receive services in the facility
  • ODP Regional Office
​Older Adult Daily Living Services
  • ​Individuals who receive services in the facility
  • Service Coordinators of individuals who receive services in the facility
  • Area Agency on Aging
  • The individuals’ Managed Care Organizations
​Structured Day Habilitation
  • ​Individuals who receive services in the facility
  • Service Coordinators of individuals who receive services in the setting
  • OLTL
  • The individuals’ Managed Care Organizations


III. Re-opening Guidance

When a Older Adult Daily Living Center, Structured Day Program, LIFE Day Center, Adult Training Facility or Vocational Facility is closed due to a substantial rate of community spread within the county where the facility is operated, or staff or an individual who spent any time in the facility is diagnosed with COVID-19, the impacted provider should complete the Community Participation Support and Older Adult Facility (CPS/OAF) Re-opening Tool (attached). The Re-opening Tool will help facilitate agency planning, policy development, and guide decision making for technical assistance and the involvement of other available resources (ex. DOH, Regional Response Health Collaboration Program [RRHCP]). 

When an Older Adult Daily Living Center, Structured Day Program, LIFE Day Center, Adult Training Facility, or Vocational Facility is closed due to substantial community spread, the impacted provider should use the CPS/OAF Reopening Tool to review its infection control protocols and mitigation strategies and to ensure that all returning staff and individuals are prepared to implement the protocols and strategies upon return to the facility. The completed ReOpening Tool may be sent to the designated oversight office listed below for informational purposes.

Completing the Re-opening Tool

      • Section 1 – Provider Details: Provider should complete this section by responding to each field. Providers should identify the oversight office. For “dual licensed” Older Adult Day and Adult Training facilities, PDA regional licensing representatives are the designated oversight office. A completed copy of the tool should also be sent to the respective Administrative Entity.
      • Section 2 - Reason for Temporary Closure: Providers complete this section by checking all reasons/details that apply to the closure. Responses will assist with determining the need for technical assistance and locating additional resources (ex. DOH, RRHCP)
      • Section 3 – Re-opening Activities: Providers complete this section by reviewing each “Re-opening Area,” describing policy modifications, and checking each area as “complete.” Providers should mark “N/A” (not applicable) if the re-opening area has not impacted the provider’s current COVID-19 plan.
      • Section 4 – Oversight Review: The identified oversight office with complete this section after reviewing (1) information provided in the Re-opening Tool and (2) the provider’s updated COVID-19 plan. Oversight offices will provide additional technical assistance as requested and needed.

Once complete, the provider submits the Re-opening Tool electronically to the designated oversight office as follows:

      • ODP – Submit electronically to designated Administrative Entity (AE)
      • OLTL – Submit electronically to the following address: RA-PWLIFE@pa.gov
      • PDA – Submit electronically to the designated regional licensing representative

The oversight office will review and respond to the provider’s submission within 48 hours. The oversight office will either indicate that the facility has addressed/updated areas of the re-opening guidance or schedule time to discuss the Re-opening Tool results, including the identification of additional support or technical assistance. 

Attachment

A. ODP Community Participation Support Re-opening Matrix 

​Facility Status
​Reason
​Provider Action
​Technical Assistance
Closed
​CPS facility did not reopen since initial March closure
​Review and complete the Facility Based Community Participation Supports Readiness Tool for COVID-19
​Administrative Entities
​Closed

​Staff or individual tests positive

​Complete the CPS and Older Adult Day Program Re-opening Tool
  • ​Administrative Entities
  • Department of Health for contact tracing
​Closed
County exceeds Community Spread Threshold

​Complete the CPS and Older Adult Day Program Reopening  Tool
​Administrative Entities for Informational Purposes
Open
No positive tests and low/moderate community spread
​Continue to monitor weekly County Community Spread via the Early WarningMonitoring SystemDashboard and keep program/facility COVID-19 plan up-todate.
​Administrative Entities

B. Theshold for Community Spread Table 

Thresholds for Community Spread​
Level of Community Transmission
in the County​
​PCR Percent Positivity
(Most Recent 7 Days)

​Recommended Facility
Operational Status

​Low
​Less than 5 percent
​Remain open or reopen if previously closed and low threshold is met continuously over a 14-day period
​Moderate
​5 to 10 percent
​Facilities may choose to close, stay closed, remain open, or reopen if previously closed. If a facility remains open or reopens while the level of community transmission is moderate, it is recommended that the facility increase mitigation measures related to COVID-19 including, but not limited to: (1) inform participants with high risk needs of the “moderate” level of community transmission designation; (2) consider reduction in the number of service days to provide for additional cleaning; (3) reduce, or at a minimum, not expand current capacity; (4) make alternative transportation plans for anyone using public transit or multi-passenger vehicles with passengers from multiple locations.
​Substantial
​More than 10 percent
​Close or remain closed until the level of community transmission returns to and remains in low or moderate for 14 days.