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Authors Posts by Carol Ferenz

Carol Ferenz

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0 2311

ODP Announcement 19-104 provides a list of current AWC FMS organizations that are available to support participants and surrogates who have chosen to self- direct some or all their Participant Directed Services (PDS) using the AWC FMS model and are in the Consolidated, Community Living, and Person/Family Directed Support (P/FDS) waiver

ODP requires each AE to have at least one qualified AWC FMS organization to provide AWC FMS. The table at the end of this document provides a complete listing of the AWC FMS organizations and the area in which they provide services across the state.

If there are any changes to the information contained in the table, the AWC or AE should notify the regional FMS lead.

These AWC FMS organizations are not to be confused with the statewide Vendor Fiscal/Employer Agent (VF/EA) FMS organization. Currently, ODP contracts with Palco Inc. to provide FMS to waiver participants who elect to use the VF/EA FMS model.

For more information, regarding the two FMS models (AWC and VF/EA), please visit
MY ODP.org.

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The Self-Determination Housing Project of Pennsylvania is hosting a webinar; “811 Project Rental Assistance Overview” on Monday, August 19, 2019 at 10:00 am. The webinar will cover program eligibility, priority populations, how to become a stakeholder, and what the process looks like once someone is referred to an 811 unit. Please follow the link below to register for the webinar and feel free to share this information with colleagues and those in your network who would be interested in this topic.

Please register in advance for this webinar. After registering, you will receive a confirmation email containing information about joining the webinar. If you have any questions, please reach out to the 811 Team.

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ODP Announcement 19-102 provides information regarding the amendments submitted to the Centers for Medicare and Medicaid Services (CMS) regarding the Consolidated, Community Living, and P/FDS waivers. It is anticipated that the amendments will become effective October 1, 2019.

CMS has 90 days to review the amendments and changes may occur to the content based upon discussion with CMS during the approval process. Each full waiver application, as well as a side-by-side of substantive changes made as a result of public comment is available online here.

The amendments align with 55 Pa. Code Chapter 6100 regulations when effective, ensure compliance with the Home and Community-Based Settings regulations, and align with the Office of Developmental Programs’ Everyday Lives recommendations.

The amendments include a plan to serve medically complex children in a community home when transitioning from an extended hospital stay if they are unable to return to their family home. Also, the scope of professionals who can diagnose intellectual disability has been expanded.

ODP is adding the expectation that all providers of Community Participation Support services must offer individuals opportunities to participate in community activities that are consistent with the individual’s preferences, choices, and interests. On-call and remote support is proposed in order to support the fading of service and dependence on paid staff. The number of procedure codes and staffing levels has been decreased to more accurately reflect service delivery.

Starting January 1, 2022, CPS services may not be provided in any facility required to hold a 2380 or 2390 license that serves more than 150 individuals at any one time, including individuals funded through any source. All participants receiving prevocational services must have a competitive integrated employment outcome included in their service plan. There must be documentation in the service plan regarding how and when the provision of prevocational services is expected to lead to competitive integrated employment. CPS may not be provided in newly funded (on or after January 1, 2020) licensed 2380 or 2390 locations which serve more than 25 individuals in the facility at any one time.

Residential Habilitation, Life Sharing, and Supported Living Services will be required to utilize the recommendations provided in the Health Risk Screening Tool. SCs will be expected to monitor the implementation of the recommendations and incorporate them into the Individual’s Plan. Also, clarification is provided regarding the location parameters for newly funded sites.

ODP is proposing that respite can be provided by nurses for children with medical needs to assure the appropriate level of care is available.

Qualifications required for Support Service Professionals, Individuals, and Agency Providers have been clarified, including timelines for completion of certification requirements. Additionally, supported employment can be provided to individuals until OVR services are available, particularly when OVR has established a waiting list.

For a side-by-side comparison of substantive changes made as a result of public comment, see this online document. Questions about this communication should be directed to the appropriate ODP Regional Office.

0 1802

ODP published a revised version of Announcement 19-098 to provide guidance regarding when Individual Support Plan (ISP) team meetings must be held to address identification of staffing ratios for facility time in the provision of Community Participation Support (CPS) services.

While many individuals receiving CPS services choose to use the service to access their communities, some individuals also choose to receive this service in facility settings licensed under 55 Pa. Code Chapters 2380 and 2390. For facility-based providers that have significant movement of people between facility-based and community-based CPS services during the course of a day, this can create facility staffing ratios that do not reflect what is authorized on an ISP. This communication offers guidance for when staffing ratios change due to individuals leaving the facility to engage in community activities.

To identify the facility staffing ratios that should be included in each ISP, teams should consider the following at each annual ISP meeting:

  • The maximum staffing ratio in which the individual’s health and safety needs can be met and the individual can be supported to meet the programmatic goals identified for that individual in the facility; and
  • The likelihood that, due to programmatic demands for time supporting individuals in community, the ISP should include an authorization for the next lowest staffing ratio. This does not apply when the maximum staff ratio identified in the first bullet is 1:1 or 2:1.

The provider must have documentation that supports these staffing ratio changes, and the different staffing ratios must be in each individual’s ISP. If or when the individuals return from their community activity and rejoin the original group, the provider then must bill at the original staffing ratio. Changes to staffing ratios as discussed in this communication may not be added or authorized in the ISP with a retroactive effective date.

An ISP team meeting is not required to add the appropriate procedure code to the ISP for the next lowest staffing ratio in accordance with this communication. ODP will only allow requests for staffing ratio changes rendered in a facility when the change is related to the occurrence of others receiving CPS in the “community,” not for instances when staffing ratios would change due to individuals that are unable to receive CPS services (ex. illness, injury, vacation, etc.).

For individuals receiving CPS services in facilities in which engagement in community activities impacts the staffing ratios within the facilities, Individual Support Teams should discuss the appropriate facility staffing ratios to be included in the ISP. Where applicable, an ISP may include authorizations for two staffing ratios for facilities.

Changes to staffing ratios as described in this communication may be approved for a P/FDS cap exception. P/FDS cap exceptions should be identified by the ISP team and a request should be submitted to the Administrative Entity no later than August 15, 2019. The Administrative Entity will submit exception requests to their ODP designated Regional Office for review no later than August 30, 2019. ODP approvals will be communicated to the Administrative Entity. Questions about this communication should be directed to your ODP Regional Program Office.

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Office of Developmental Programs Bulletin 00-19-03 Prioritization of Urgency of Need for Services (PUNS) was published on July 23, 2019. The purpose of the bulletin is to distribute the updated PUNS Manual. Additional materials include the PUNS Form, the PUNS cover letter, and the PUNS Disagreement Form. The PUNS Form and the PUNS Disagreement Form will be translated into Spanish; ODP will release a communication once the forms are translated.

When PUNS was first implemented in 1998 and revised in April 2006, a manual was published to provide instructions on the completion of the form. The PUNS Manual was updated to reflect circumstances that better identify the individual’s and family’s experiences throughout the individual’s lifespan. It also provides new instructions for completing the form, emphasizing that is to be completed in its entirety through a face-to-face conversation between the Supports Coordinator, the individual, and family.

The PUNS Form cannot be handed or sent to the individual and family to complete on their own; however, the form can be shared with the individual and family in advance of the meeting at their request so they are prepared when meeting with the SC.

A copy of the finalized HCSIS PUNS Form and PUNS cover letter must be sent to the individual and family within five working days of finalization of the HCSIS PUNS Form. The HCSIS PUNS should contain the same information as the PUNS Form completed during the meeting. The HCSIS PUNS reflects the service needs captured at the meeting.

The PUNS is a tool used to determine the need for ID/A services and establishes the priority of need for services when there is a waiting list for the County Program or AE to provide services as requested. The information in PUNS is reviewed and updated if needed during the annual Individual Support Planning (ISP) process and as an individual’s needs change.

The PUNS indicates the urgency of need for services. The urgency of the need is identified in one of three categories:

  • Emergency Need → the service need will occur within six months;
  • Critical Need → the service need is anticipated to occur after six months but within two years; and
  • Planning for Need → the service need is anticipated to occur more than two years away but less than five years away.

If there is disagreement with the results of the PUNS, the PUNS Disagreement Form has detailed instructions for the individual and family to indicate disagreement with the information on the finalized PUNS Form. Concerns should be noted on the PUNS Disagreement Form and returned to the SC within 10 calendar days of receipt of the finalized HCSIS PUNS Form. The Disagreement Form will be reviewed in attempt to resolve the concerns. The SCO must contact the individual and family within seven calendar days of receipt of the Disagreement Form to initiate a review of the concerns with the individual and family and why they disagree with the PUNS Form.

Effective July 23, 2019, Bulletin 00-06-15, Prioritization of Urgency of Need for Services (PUNS) Manual, is obsolete.

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Today — Friday, August 2 — ODP staff emailed a survey to providers of CPS. It is very important that providers complete the survey to the best of your ability in order to document actual costs of providing CPS.

The email states, “ODP and the Community Participation Support (CPS) Implementation Workgroup are seeking your input on the enclosed survey questions. These questions are intended to inform rate assumptions associated with CPS provided in licensed facilities in response to concerns raised during the public comment period for the Final Fee-schedule Rates for FY 19/20. We are requesting survey responses by August 11, 2019. Thank you for your participation.”

We have learned that some members discovered the email in their spam or junk email, so please be aware that it was sent. The email came from Ashley Senoski — [email protected] — and the subject line is: “Current ODP Providers of Facility-based Community Participation Supports.”

If you are a provider of facility-based Community Participation Supports and did not receive the survey to complete, please contact Ashley at the email address above.

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