ODP Announcement 19-098 provides direction to providers regarding adjustments that may be made to ISP billing codes when the size of the group remaining at the facility changes as a result of others leaving the facility to access the community. Effective July 1, 2019, ODP implemented simplified procedure codes and staff to individual ratios to make planning, authorizing, and billing for Community Participation Support (CPS) services more efficient and to reflect service delivery more accurately. The procedure codes and staffing ratios were first introduced in ODP Communication 19-024. Staffing ratios for services provided in facility settings are: 1:11 to 1:15; 1:7 to 1:10; 1:4 to 1:6; 1:2 to 1:3; 1:1; and 2:1.

During CPS service provision, as individuals leave the facilities to access the community, staffing ratios for individuals who remain in the facility may be adjusted to better reflect the actual staff to individual ratio provided. To identify the facility staffing ratios that should be included in each Individual Support Plan (ISP), teams should consider the following:

• 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.

For example, in situations where a group of individuals is receiving CPS services in a facility at a 1:4 to 1:6 staffing ratio, but several individuals in that group leave the facility to engage in a community activity on a regular basis, leaving a de facto 1:2 to 1:3 group in the facility, the provider can bill for 1:2 to 1:3 for the smaller group continuing to receive services in the facility. This supports providers in promoting community inclusion. 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 1:4 to 1:6 facility rate. Changes to staffing ratios as discussed in this communication may not be added or authorized in the ISP with a retroactive effective date. ODP will not allow requests for staffing ratio changes due to instances when individuals are unable to receive CPS services (when individuals are ill, injured, on 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 based on the above criteria, 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.