DHS COVID-19 PROVIDER GUIDANCE // OLTL
Operational Recommendations for Long-Term Service and Support (LTSS)
Providers
Issued: March 13, 2020
In response to growing concerns about the spread of COVID-19 and its potential impact
on the delivery of services to individuals receiving LTSS, the Department of Human
Services, Office of Long-term Living (OLTL) has developed the following operational
recommendations for LTSS providers. Information will be updated and released on
a recurring basis as new information becomes available.
Information will continue to be shared and disseminated going forward to address
questions and concerns that have been brought to our attention. We continue to monitorinformation from the Pennsylvania Department of Health (DOH) and the U.S. Centers for Disease Control and Prevention (CDC). Guidance developed by DHS will be
centrally located on this page, which will be updated as additional guidance becomes
available. We encourage you to continue to consult these resources for updates on
COVID-19, information on staying healthy, and updates on the situation in
Pennsylvania.
Additionally, OLTL is collaborating with the Centers for Medicare and Medicaid Services
(CMS) to make emergency amendments to its Community HealthChoices (CHC) and
OBRA Waiver in response to COVID-19. The amendments under development provide
for flexibility that may be necessary to continue ensuring the health and safety of CHC
participants. The types of modifications and flexibility OLTL is seeking include but are
not limited to the following areas: remote/telephonic service coordination; revised
processes for level of care and annual redeterminations; person centered service
planning; and where certain services can be provided. Additional information about the
amendments will be provided in subsequent releases of this document.
Recommendations
Recommendation #1: Exercise and promote hygienic practices.
The best way to prevent illness is to avoid being exposed to COVID-19. Providers
should remind staff that chances of exposure can be reduced by:
- Washing hands often with soap and water for at least 20 seconds especially after
being in a public place, or after blowing noses, coughing, or sneezing.
- Using a hand sanitizer that contains at least 60% alcohol if soap and water is not
readily available. People should cover all surfaces of hands and rub them
together until they feel dry.
- Avoiding touching eyes, nose, and mouth with unwashed hands.
- Covering mouths and noses with a tissue when coughing or sneezing or using
the inside of their elbow.
- Cleaning AND disinfecting frequently touched surfaces daily. This includes
tables, doorknobs, light switches, countertops, handles, desks, phones,
keyboards, toilets, faucets, and sinks.
- Staying home if sick.
Recommendation #2: Review your agency back-up plan and infection control
procedures.
All OLTL providers are strongly encouraged to:
- Review internal infection control protocols and emergency backup plans for
events in which a provider does not have adequate staffing to meet individuals’
health and safety needs.
- Evaluate staff adherence to provider infection control protocols.
- Evaluate capacity to implement emergency backup plans in the event staffing is
impacted by the COVID-19 virus.
Resources for Infection Control Practices:
Recommendation #3: Report all suspected cases of COVID-19 to DOH and OLTL
and/or the participant’s CHC-MCO
Suspected cases should always be reported first to DOH at 1-877-PA-HEALTH. For
OLTL and the CHC-MCOs to be responsive to the needs related to COVID-19, timely
information from the provider community is essential. If staff or a person for whom you
provide services appears to be symptomatic or tests presumptively positive for COVID19, please notify the CHC-MCOs or the appropriate OLTL program area for non-CHC
participants using the contact information below. In addition, providers should also
contact DOH.
Recommendation #4: Contact OLTL before making any changes to your business
practice whenever possible.
It is strongly recommended that providers contact the three CHC-MCOs and OLTL
before making any changes to their business practices in response to COVID-19.
Examples of changes in business practices include, but are not limited to:
- Suspending services at a service location, such as an Adult Day or Structured
Day Habilitation Program;
- Reducing or eliminating the provision of community-based activities;
- Restricting individuals’ abilities to receive services based on health status; and
- Restricting visitors in nursing facilities, Personal Care Homes or Assisted Living
Residences.
OLTL is monitoring the COVID-19 situation closely and is prepared to modify
expectations for compliance with contacting OLTL before making any changes to your
business practice, on a case-by-case basis should emergency conditions present. By
contacting the CHC-MCOs and OLTL, providers may be able to implement the most
effective strategy for maintaining continuity of operations during COVID-19 outbreak.
Providers may contact the CHC-MCOs and OLTL using the following contact
information to notify OLTL of a proposed change in business practice and/or seek
guidance related to a proposed change.
Recommendation #5 LTSS Residential Providers Should Follow State and
Federally-Issued Guidance
Nursing facilities, assisted living facilities, personal care homes, and residential
habilitation providers should follow the guidance issued by DOH, CDC, and CMS,
including monitoring and restricting visitors: https://www.cms.gov/files/document/qso-20-
14-nh-revised.pdf
Recommendation #6: Document any actions that were taken and maintain
evidence for why actions were taken.
Providers should document any changes to their operations as a result of COVID-19
and maintain evidence to support why the changes were made. Doing so will help
demonstrate the basis for an action in the event that the appropriateness of the action is
questioned after COVID-19 is contained and operations return to normal. It will also
support any changes that may need to be made to Person-Centered Service Plans and
substantiate claims for services rendered in an alternative manner due to a COVID-19.
OLTL and the CHC-MCOs will provide technical assistance with the kind of evidence
that should be maintained when providers contact OLTL in accordance with
Recommendation #4. In general, evidence that should be maintained includes, but is
not limited to:
- Orders or notices from local authorities. Example: County Health Department
A imposes a restriction on public gatherings of more than 20 people, forcing
Provider B to close its adult day center. Provider B should retain the official
notice from County Health Department A as evidence to support the closure.
- Correspondence and other records demonstrating inability to meet
required staffing requirements. Example: Provider A’s provider-employed
direct care workers (DCW) are unable to report to work due to COVID-19-related
reasons. Provider A attempts to secure temporary staff from three staffing
agencies, but each agency reports that they too are experiencing staff shortages.
Provider A should retain copies of correspondence with each of the three staffing
agencies to demonstrate that all possible efforts were made to secure enough
staff
Recommendation #7: Stay Informed
- DOH holds daily press briefings to announce the latest efforts and updates on
the commonwealth’s response to COVID-19. Providers may watch a free live
stream of the daily briefing at noon here. An archive
of past briefings is available here.
- As a provider of long-term services and support services, one of the most
important steps you can take to stay informed about our program is subscribe to
our Listservs. Important announcements, including announcements about
COVID-19, are regularly sent over the Listservs.
- COVID-19-specific information can be found at:
- The DOH’s Coronavirus Update Page