Thanks to all the members who joined our last Membership Meeting on August 26, 2022. Special THANKS to our colleagues Julie Mochon and Laura Cipriana from ODP who provided great information on PA’s Statewide Transition Plan for HCBS, the recently released ISP Bulletin and the June 1, 2022 Amendments, the ID/A Renewals, and a discussion on the recently updated Technical Guidance for Claim and Service Documentation.
You can access the attachments and information from the meeting below:
- Agenda
- Link to the Recorded Session
- ODP PowerPoint Presentation
- Reference Attachments:
- ODP Technology Task Force Newsletter
- ODP Bulletin 00-22-03 Technical Guidance for Claim & Service Documentation
- ODP Bulletin 00-22-05 Individual Support Plans
- TPA Public Comment Letter for Additional ARPA Funding
- ODP Announcement 22-096 Open Comment Period for the Statewide HCBS Transition Plan
- ODP Announcement 21-090 Guidance for the use of Assistive Technology & Remote Supports in a Residential Setting
- Advocacy Campaign – Discontinuance of Prudent Pay Policy
During our discussion, we had some questions on expectations for compliance with the HCBS Rule in recognition of the workforce shortage. ODP provided a reference to that guidance, and it is below. Providers should continue to follow the Operational Guide, waivers, and regulations regarding service delivery. ODP will communicate if there are changes in expectations for service delivery. Please let us know if your members are concerned about compliance with any specific requirements that are currently in place.
Expectation: All states and settings will be fully compliant with the following regulatory settings criteria that are not impacted by the COVID-19 PHE, including its exacerbation of the workforce shortage, by the end of the transition period.
- Privacy, dignity, respect, and freedom from coercion and restraint; and
- Control of personal resources.
Expectation: All states and provider-owned and controlled residential settings will be fully compliant with the following regulatory settings criteria that are not impacted by the COVID-19 PHE, including its exacerbation of the workforce shortage, by the end of the transition period.
- A lease or other legally enforceable agreement providing similar protections;
- Privacy in their unit, including lockable doors, and freedom to furnish or decorate the unit;
- Access to food at any time;
- Access to visitors at any time;
- Physical accessibility; and
- Person-centered service plan documentation of modifications to relevant regulatory criteria.
For the settings criteria that fall outside of those described above, states and providers must implement these remaining criteria to the fullest extent possible in light of the circumstances caused by the PHE and develop a plan and timeline for full implementation, either as part of or separate from their STP.
When the ability to support individuals to fully integrate into the community as they desire is impacted by PHE disruptions, including staffing shortages, states and providers must still ensure that the operating policies of the setting are aligned with the regulatory criteria, in a manner that facilitates individual autonomy and community participation as key components of service delivery models to the fullest extent possible.
