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Authors Posts by Carol Ferenz

Carol Ferenz

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On February 5, 2020, ninety-nine members of the House of Representatives signed and sent a letter to Seema Verma, Administrator, Centers for Medicare and Medicaid Services (CMS), that questions the proposed eight percent cut to therapy services. The proposed cut was included in the calendar year (CY) 2020 Medicare Physician Fee Schedule (MPFS) final rule that was published on November 15, 2019. The letter contained two questions asked of CMS, including the methodology and data that were used in this decision making. The responses to these questions were requested by February 21, 2020. Contact RCPA Rehabilitation Services Division Director Melissa Dehoff with questions.

ODP Bulletin 00-20-02 provides the Office of Developmental Programs’ (ODP) requirements and standardized processes for preparing, completing, documenting, implementing, and monitoring Individual Support Plans (ISPs) to ensure they are:

  • Developed to meet the needs of the individual.
  • Developed and implemented using the core values of Everyday Lives: Values in Action, LifeCourse Principles, Positive Approaches and Practices, and Self Determination to result in an enhanced quality of life for every individual.
  • Compliant with the approved Consolidated, Community Living, and Person/Family-Directed Support (P/FDS) Waivers and MA State Plan as it pertains to Targeted Support Management (TSM).

This bulletin and attachments have been updated to align with the October 1, 2019 amendments of the Consolidated, Community Living, and P/FDS Waivers and provide clarification regarding approved waiver service definitions.

A full ISP is required for any individual who:

  • Is enrolled in the Consolidated, Community Living, or P/FDS Waiver.
  • Receives Targeted Support Management.
  • Is not eligible for Medical Assistance and receives $2,000 or more in non-waiver services in a Fiscal Year.

Or

  • Is eligible for Medical Assistance and in reserved capacity for waiver enrollment.

An abbreviated ISP may be completed for any individual who is not eligible for Medical Assistance and receives under $2,000 in non-waiver services in a Fiscal Year. Base-Funded Case Management services are not included in the $2,000 limit. Administrative Entities or Supports Coordination Organizations still have the option of completing a full ISP and are encouraged to do so.

All ISPs, including abbreviated ISPs, must:

  • Be completed using the standardized format in the Home and Community Service Information System (HCSIS).
  • Be based on assessed needs of the individual.
  • Be developed using a person-centered planning process to capture information including health and welfare and the individual’s preferences and desires, all of which are intended to identify and implement appropriate services and supports.
  • Be updated, approved, and have services authorized at least annually (every 365 calendar days) and when warranted by changes in the individual’s needs.
  • The Consolidated, Community Living, and P/FDS Waivers state that ISPs for individuals enrolled or enrolling in any of these waivers must contain the following additional information:
    • All unpaid natural supports and funded supports to meet assessed needs. The ISP shall include documentation of services provided through other agencies (for example, Insurance, Office of Vocational Rehabilitation, Aging, Drug and Alcohol, and Education).
    • The frequency, amount, type, and duration of each service.

Further, the Consolidated, Community Living, and P/FDS Waivers stipulate that Supports Coordination Organizations (SCOs) must ensure that ISPs are thoroughly reviewed to assure services accurately reflect an individual’s needs prior to submission to the Administrative Entity for approval and authorization. Upon receipt of the ISP, the Administrative Entity is responsible for:

  • Ensuring all necessary services (both paid and unpaid by ODP) are included on the ISP prior to approval.
  • Ensuring the services are eligible for reimbursement prior to approval and making a service authorization decision.

Once the ISP is approved and authorized by the Administrative Entity, the Supports Coordinator is responsible to provide a completed copy of the signature form to all team members and distribute all approved ISPs to all appropriate team members unless otherwise requested. Providers that have access to the approved ISP in HCSIS are responsible for distributing the ISP to all appropriate staff within their agencies.

ISPs are not required, but are encouraged, for individuals residing in an Intermediate Care Facility for Persons with an Intellectual Disability (ICF/ID). For individuals residing in ICFs/ID, the ICF/ID personnel are responsible for developing the individual plan (outside of HCSIS) in accordance with ICF/ID regulations. This includes ensuring that services in the plan meet the individual’s needs. Although Supports Coordinators are not required to develop an ISP for individuals residing in State Centers and private ICFs/ID, they are responsible for maintaining regular contact with the ICF/ID facility, evaluating the individual, and participating in plan development as required under the County Intellectual Disability Service regulations – see 55 Pa. Code §6201.14 (relating to aftercare services). For individuals residing in State Centers and private ICFs/ID, the County Program is not responsible to authorize the plan.

ATTACHMENTS:

OBSOLETE DOCUMENTS:

  • Bulletin 00-17-03, Individual Support Plans for Individuals Receiving Targeted Services Management, Base Funded Services, Consolidated, or P/FDS Waiver Services or Who Reside in an ICF/ID.
  • ODP Communication 023-18, ISP Manual Update: Life Sharing Codes in the Consolidated and Community Living Waivers
  • ODP Communication 012-18, ISP Manual Update: Respite Camp Codes in the Consolidated, P/FDS, and Community Living Waivers.

The Chapter 6400 Regulatory Compliance Guide, or RCG, was released for immediate implementation on February 3, 2020. ODP will be presenting a live webinar about the purpose of the RCG and how it will be used for applying and enforcing Chapter 6400. General information about why RCGs are used will also be presented.

This session is open to providers, advocates, Administrative Entities, Supports Coordinators, and all other interested parties.

Two additional sessions have been made available:
Tuesday, February 18, 2020 • 9:00 am – 12:00 pm and 1:00 pm – 4:00 pm
To register, use this link.

ODP Announcement 20-012 announces that in order to build provider capacity statewide, ODP is broadening the provider qualifications of the Benefits Counseling service. As of the date of this communication, ODP will accept the Work Incentive Practitioner credential for staff (direct, contracted, or in a consulting capacity) who will work directly with the participant to provide Benefits Counseling.

The Work Incentive Practitioner credential is obtained by completing the Cornell University Work Incentives Planning & Utilization for Benefit Practitioners Online Certificate course and satisfying requirements to maintain the credential (sixty hours of continuing education units for training approved by Cornell University within 5 years of obtaining the full credential).

To be determined qualified to render the Benefits Counseling service in accordance with this guidance, providers must submit documentation of each staff person’s current Work Incentive Practitioner credentials to their Administrative Entities. Information about the credentialing course can be found here.

ODP will continue to accept the Community Work Incentive Coordinator (CWIC) Certification offered through Virginia Commonwealth University. Changes to the Provider Qualifications section in the Consolidated, Community Living, and P/FDS waivers will be made during the next amendment. For questions, please submit via email.

Employment First Community of Practice Monthly Webinar – Wednesday, February 12, 2020

Travis Akins, Founder and CEO, will showcase the highly innovative Growth Through Opportunity (GTO) Cadets training program and the unique methodology behind achieving high employment rates for adult individuals with intellectual and developmental disabilities (I/DD). [Read full article]

ODP Announcement 20-011 provides the updated process for providers to request an enhanced communication rate for Consolidated, P/FDS, and Community Living Waiver services for d/Deaf individuals who use Sign Language to communicate. The enhanced communication rate is available for services from providers who have signing staff to serve d/Deaf individuals. In the Consolidated, P/FDS, and Community Living waivers, this rate is available for the following services:

• Small Group Employment
• Benefits Counseling
• Supported Employment
o Career Assessment
o Job Finding and Development
o Job Coaching and Support
• Advanced Supported Employment
o Discovery Profile Outcome
o Job Acquisition Outcome
o Job Retention Outcome
• Respite
• Supports Broker Services
• Housing Transition and Tenancy Sustaining
• Residential Habilitation
• Companion Services
• In-Home and Community Supports
• Community Participation Supports
• Shift Nursing RN
• Shift Nursing LPN
• Therapies
o Physical
o Occupational
o Speech/Language
o Orientation, Mobility, and Vision
• Music Therapy
• Art Therapy
• Equine Assisted Therapy
• Behavioral Supports
• Communication Specialist
• Consultative Nutritional Services
• Family Caregiver Support Counseling (with participant present)
• Supplemental Habilitation
• Supported Living
• Life Sharing

See the announcement to read the full process to request an Enhanced Communication Rate and the updated Enhanced Rate Request form.

ODP Announcement 20-009 provides an updated Provider Closure Notification Form (DP 1061) and instructions to comply with 55 Pa. Code § 6100 requirements. The Provider Closure Notification Form is used to ensure that all ODP waiver and system requirements are met for any provider who no longer intends to provide ODP Consolidated, Person/Family Directed Support (P/FDS), and/or Community Living Waiver services. This includes ensuring that participants who are receiving services from the closing provider are properly transferred to a willing and qualified provider of their choice, according to 55 Pa. Code § 6100.303, and that the closing provider is properly removed from the ODP systems, including but not limited to HCSIS and PROMISe.

Providers are required to use the Provider Closure Notification Form (DP 1061) to ensure that ODP and all authorizing AEs are notified of their closing, in accordance with 55 Pa. Code § 6100.304. The 11/19 revised version of the DP 1061 can be found on the “Forms” page of MyODP.org and has been formatted to be submitted electronically. This new version of the form (11/19) should be used going forward effective immediately.

This form is not to be used when providers are ONLY discharging individuals. Providers shall adhere to requirements contained in 55 Pa. Code § 6100.304.

With the release of this announcement, ODP Communication Number: 050-17 Provider Closure Notification Form (DP 1061) is obsoleted. COMMENTS relating to the Provider Closure Notification Form (DP 1061) may be directed to the ODP Provider Qualification mailbox.

Certified Investigator class offerings for the Initial Certified Investigator (CI) Courses are available on MyODP.org. The Initial Certification Course includes an online prerequisite course, four days of face-to-face training, and an online exam created to ensure all incidents that require an investigation receive a systematic investigation that meets established standards. In order to perform investigations, the investigator must successfully complete all requirements of the ODP CI Initial Certification Course. Once all activities are completed within the current standards, the participant will be certified for three years. Please review the guide for instructions on how to register.

For assistance with registration, please contact support@myodp.org.
For questions regarding the course or its topic, please contact sarah.naughton@temple.edu.

The following trainings are offered during the month of February. Details are available here.

  • Wednesday, 2/19/20 1:00 pm – 3:00 pm: Balancing the Family Perspective and Participant’s Desires
  • Monday, 2/24/20 10:00 am – 11:30 am: An Overview: Charting the LifeCourse
  • Monday, 2/24/20 11:00 am – 12:15 pm: Eligibility Training Webinar for Administrative Entities
  • Thursday, 2/27/20 1:00 pm – 2:00 pm: How Ethical Philosophies Drive Our Decision Making
  • Thursday, 2/27/20 2:30 pm – 3:30 pm: Quality Assessment and Improvement (QA&I) Annual Comprehensive Statewide Report Cycle1 Year 2 (C1Y2)

Virtual Office Hours (VOH) are GoToWebinars that allow interactive dialogue. They occur one time and are not recorded.

Virtual Targeted Trainings (VTT) are GoToWebinars that include PowerPoint presentations. They have minimal opportunity for dialogue but are recorded.

Pre-registration for each session is required. Use the linked title in the schedule attached to this message to register. Once registered, you will receive an email with instructions describing how to participate including a new link to join the meeting. You can join the audio portion of the webinar by telephone or computer.

For questions or for an accessible version of the attachment, please use this email.