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Tags Posts tagged with "OLTL"

OLTL

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The Office of Long-Term Living (OLTL) has published responses to questions brought up at the Long-Term Services and Supports (LTSS) Subcommittee meeting held on February 5, 2025.

The highlights include:

  • All consumer questions about the specifics of the Assisted Living In Lieu of Services should be addressed to the MCOs.
  • The information about Personal Needs Allowance in Personal Care Homes has been corrected. “SSI recipients will receive a PNA deduction of $52.10 ($30 SSI plus the individual state supplement of $22.10).”
  • Any organization who is interested in participating in the Direct Care Worker Quality Grant should contact Abigail Peslis, Director of Penn State Harrisburg Continuing Education.

If you have any questions, please contact Fady Sahhar.

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The Long-Term Services and Supports (LTSS) Subcommittee meeting convened on February 5, 2025. During the meeting, a number of presentations were given. In addition to the presentations, the February meeting agenda and the meeting transcript from the January 8, 2025, LTSS Subcommittee meeting were provided.

Members should take time to review the PowerPoint presentations from the meeting:

The meeting transcript is available here.

The next LTSS Subcommittee meeting is scheduled for March 7, 2025, from 10:00 am – 1:00 pm and will be held via webinar and remote streaming.

To participate in the meeting via webinar, please register here.
If calling into the meeting, the dial-in information is: 1 (562) 247-8422; Access Code: 145-307-305#

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As was shared in the RCPA Alert sent on Tuesday, January 28, the House Human Services and Insurance Committees held a joint informational meeting on January 29 on Traumatic Brain Injury (TBI): Care Needs and Coverage Options, where testimony was provided by RCPA, OLTL, Success Rehabilitation, BIAPA, and insurers.

Following the hearing, leadership from the House Human Services Committee has requested additional information from BI providers. Please review the questions below and provide responses to Melissa Dehoff by close of business Monday, February 3.

  1. Is your organization accredited by CARF as a Brain Injury Residential Rehabilitation Program (Adult) or Community Housing?
  2. Do you provide other non-residential services through the waiver? If so, please list them.

The important message to share is that we have the legislators’ attention! Things are moving very quickly; there are many meetings, calls, and ongoing communications with leadership in the legislature as we enter the key phase of budget negotiations.

It is critical that we have full participation in providing this information from every single BI provider/program. If we do not provide responses from 100% of our BI members, it could have an impact on funds being allocated to us in the budget.

Please contact Melissa Dehoff with questions and your responses.

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The Office of Long-Term Living (OLTL) is partnering with the Office of Developmental Programs (ODP), The Institute on Disabilities at Temple University, College of Education and Human Development, and the University of Kansas Center on Disabilities’ State of the States team to host Pennsylvania Technology Summits as part of a statewide initiative called PA Tech Accelerator.

The goal of the Summits is to expand the awareness of, and access to, assistive technology and remote technologies in order to build capacity of technology users throughout the Commonwealth of Pennsylvania.

The Summits will be held on March 6, 2025, in Philadelphia and March 13, 2025, in Pittsburgh. To attend, please register here.

The Summits will feature a keynote address by Rebekah Taussig, PhD; a panel of technology users giving advice, sharing their stories, and answering questions; and vendors showcasing services, devices, and solutions.

Who is invited?

  • People with disabilities and their families.
  • Direct Support Providers and professionals working with people with disabilities, such as Direct Care Workers, Direct Support Professionals, Support Service Professionals, Supports Coordinators, Job Coaches, and healthcare professionals.
  • Organizations and providers who serve people with disabilities.
  • Policymakers, advocates, and allies for people with lived disability experience.
  • Students looking to work in disability-related fields.
  • Anyone interested in technological supports for people with disabilities.

If you have additional questions about the Summit, please contact Kristy Crocetto at (215) 204-1356 or via email.

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Young caregiver helping older lady to stand up

The Office of Long-Term Living (OLTL) recently shared additional guidance for providers related to the Centers for Medicare & Medicaid Services (CMS) Home and Community-Based Services (HCBS) Settings Final Rule.

This clarification applies to Residential Habilitation and Personal Care Home Providers.

Regulations at 42 CFR 441.301(c)(4)(vi)(B) require that participants in residential settings have the ability to close and lock doors within their living units. As a part of the Office of Long-Term Living (OLTL) residential provider reviews, it was found that several sites did not meet this requirement. As remediation, some providers opted to have participants sign a form stating that they do not wish to have a lock on their doors, which OLTL’s settings review panel accepted as compliant.

The Centers for Medicare & Medicaid Services (CMS) has reviewed OLTL’s oversight activities and has deemed that participant sign-off waiving installation of locks does not sufficiently satisfy the requirement. CMS has determined that all doors with access to participant units or private spaces (such as a bedroom) must have locks installed. The participant’s choice is whether to utilize the lock or not. Based on this feedback, as OLTL moves forward with ongoing oversight of HCBS settings requirements, all doors to participant units/private spaces in residential settings will be required to have working locks in order to be deemed compliant for future settings reviews.

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The Long-Term Services and Supports (LTSS) Subcommittee has released its agenda for the February 5 virtual meeting. The meeting will have no onsite options for attendance and will be held via webinar at 10:00 am – 1:00 pm. You can view the agenda, which includes the webinar link, here.

The key agenda items are:

  • Office of Long-Term Living (OLTL) Updates
  • Assisted Living Residences — In Lieu of Services Policy Updates
  • Assisted Living Residences and Personal Care Homes — MCO Updates

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The Office of Long-Term Living (OLTL) Critical Incident Management Unit monitors provider compliance in the application of guidance specific to critical incident management. OLTL has identified compliance concerns and is issuing the following clarification.

This communication focuses on required critical incident notification by provider agencies to the participant’s assigned service coordinator and the documentation of such notification in the Enterprise Incident Management (EIM) entry. The OLTL Critical Incident Management Bulletin, which is also available on OLTL’s website, indicates the following:

  • Within 48 hours, the Managed Care Organization (MCO), Service Coordinator (SC), provider agency that discovers or has independent knowledge of the critical incident is to submit the First Section of the critical incident report to OLTL using OLTL’s critical incident management system. If the critical incident was discovered on a weekend or holiday, the 48 hours begin at 12:00 am on the first business day after discovery of the critical incident.
  • Providers must inform the participant’s SC within 24 hours of discovering or first learning of a critical incident.

Notification to the participant’s SC that a critical incident was discovered must not be made using the HHAeXchange system. The required notification to the participant’s SC must be made by telephone call, electronic mail communication, or any other method that is agreed upon by all parties involved, excluding the HHAeXchange system.

In addition, the notification by the provider to the participant’s SC that a critical incident was discovered must be clearly documented in the EIM incident report, specifically within the “Agencies Contacted” page. Instructions are below:

  1. Enter the first name of the SC in the Person Contacted (First Name) Field.
  2. Enter the SC’s last name in the Person Contacted (Last Name) Field.
  3. Enter the contact phone number. Note that the email address field is not mandatory; however, it should be completed when notification to the SC was made via email.
  4. Click the SAVE button when all information has been entered.

See an example of page completion below.

Providers who are experiencing difficulty meeting the Critical Incident Management Bulletin requirements may email concerns to the resource account. Additionally, questions related to critical incidents may be emailed to the Critical Incident Management team member identified in any case-specific communication.

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The Office of Long-Term Living (OLTL) issued a Critical Incident Management Bulletin, with indications that they and the Managed Care Organizations (MCO) will be enforcing these regulations. Per OLTL:

Investigation of critical incidents and its documentation is an integral part of a Service Coordinator’s (SC) responsibilities, not a stand-alone function. During the course of quality reviews, Office of Long-Term Living’s (OLTL) Incident Management staff has found that critical incident investigations are not consistently following the established policy and procedure. OLTL wants to reinforce the following requirements found in various OLTL policy and procedure documents, which remain unchanged. Non-compliance with these requirements is subject to corrective action by OLTL.

1. Investigation of Critical Incidents

a. According to the Critical Incident Management Bulletin dated 2/23/2023, Community HealthChoices (CHC) managed care organizations (MCO) and SC must begin investigating a critical incident within 24 hours of discovery or of learning of the incident. This requirement was also indicated in the 2015 version of the document. The bulletin reinforces the onsite visit requirement for fact finding. The critical incident facts, sequence of events, interview of witnesses, and observation of the participant and/or environment is required. The onsite investigation is not the same as a comprehensive needs reassessment or assessment of need, and it must be completed regardless of participant choice. The participant reserves the right to refuse involvement in the critical incident investigation. However, the onsite visit must be completed. The Telephone Investigation referenced in the Bulletin does not replace the onsite investigation requirement, and is meant for instances when more information is necessary to complete the incident report. For example, when a protective services investigation is occurring and the SC needs to gather details to ensure mitigation measures are in place. Please note that while required to cooperate in the investigation, SCs are not required to investigate reported allegations of abuse, neglect, or exploitation, which are referred to a protective services agency. However, SCs remain responsible for ensuring participants health, safety, and welfare by means of risk mitigation and appropriate service implementation.

b. The 24-hour requirement to initiate an investigation is not to be interpreted as one business day. The only time business days apply is when submitting a critical incident report in Enterprise Incident Management (EIM), which is required within 48 hours excluding weekends and holidays. Please note that while the investigation must be initiated within 24 hours of incident discovery/learning of the incident, the CHC-MCO and SC will still have 30 calendar days to complete the investigation. It is also important to note that the onsite visit does not necessarily have to occur within 24 hours of incident discovery as long as it occurs at a time that enables ensuring the health and welfare of the participant, and within the allotted 30 calendar days or extended due date in the case where a timely EIM report extension was requested.

c. The Critical Incident Management bulletin also indicates the following:
No further action is required when the critical incident report meets all three of the following conditions:

  1. The facts and sequences of events are outlined with sufficient detail; and
  2. Preventative action through the service plan is either not required or is implemented and documented; and
  3. The participant is not placed at any additional risk.

Therefore, CHC-MCOs and SCs must ensure that, prior to submitting the Final Section of the incident report in EIM, the participant is aware of the critical incident, its resolution, and the measures taken to prevent recurrence. This includes determining whether a comprehensive needs reassessment or assessment of need must be conducted, based on the requirements outlined in OLTL’s policy and procedure documents. The SC must also ensure thorough documentation in the critical incident report of all actions taken to ensure participants health and welfare.

2. Notice to Participant

The Critical Incident Management Bulletin indicates that:

  1. The agency staff that discovered or first became aware of the critical incident is to notify the participant (and representative if requested by the participant) that a critical incident report has been filed. This notice must be provided to the participant within 24 hours and in a cognitively and linguistically accessible format. If the participant’s representative is suspected to be involved in the critical incident, the representative should not be notified.
  2. Within 48 hours of the conclusion of the critical incident investigation, the SC must inform the participant of the resolution and measures implemented to prevent recurrence.

CHC-MCOs and SCs must ensure the required notifications are made to the participant, and document completion within the Referrals and Notifications page in the EIM critical incident report.

OLTL encourages all CHC-MCOs and SCs to review the Critical Incident Management Bulletin to ensure all requirements are met.

If you have any questions, please contact Fady Sahhar.

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