ODP Reissues Guidance on Staffing Ratios for Facility Time in CPS Services

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.