On April 16, 2020, during the Department of Human Services’ (DHS) “Third Thursday Webinar,” DHS discussed COVID-19 updates and temporary changes that have been made to assist direct care workers (DCWs), providers, personal care homes and assisted living residences.
Covid-19 Update: Long-Term Services and Supports (LTSS) Operations and Priorities
Office of Long-Term Living Priorities
With the current COVID-19 pandemic, the Office of Long-Term Living (OLTL) has established priorities that are aligned with helping providers and direct care workers (DCWs).
These priorities include:
- Keeping participants and staff safe. This includes not only the OLTL staff but providers as well.
- Minimizing potential service interruptions and provider capacity issues.
- Decreasing procedural and regulatory burdens for providers.
- Identifying sources of Personal Protective Equipment (PPE) and distribution mechanisms.
The OLTL is looking for opportunities to acquire PPE and are working to establish the most effective ways to distribute. They are collaborating with Public Partnerships, LLC; limited liability companies; the Community HealthChoices Managed Care Organizations (CHC-MCO) and other stakeholders. The OLTL has developed a prioritization for distribution with DCWs being first. Nursing facilities and home care facilities are second in this prioritization. Distributing of information and resources to all stakeholders is last.
Community HealthChoices Managed Care Organizations
The CHC-MCOs have also established priorities. These priorities include:
- Activating emergency response protocols to ensure the continuity of operations and services. The need for the CHC-MCO to maintain operations, as well as help others is critical.
- Providing provider guidance on billing and procedure codes updates and the Centers for Disease Control and Prevention (CDC) prevention measures.
- Conducing ongoing check-in calls with participants. Check-in calls are being made to verify back-up plans in case of interruptions.
- Identifying any unmet needs (i.e. access to meals) and ensuring participants have access to essential home items (i.e. medical supplies).
- Distributing participant COVID-19 resources including fact sheets, safety information and behavioral health resources.
Participant-Directed Services Updates
Public Partnerships, LLC (PPL) has implemented an expedited enrollment process for new DCWs to address any potential gaps in services. PPL is compiling a variety of resources, including webinars and frequently asked question sheets (FAQs) for DCWs and common law employers. As mentioned previously, PPL is collaborating with OLTL and CHC-MCOs to distribute PPE to participant-directed workers.
LIFE Program Updates
On March 17, 2020, 58 LIFE provider locations closed. LIFE providers have shifted services to home care delivery; however, they are able to utilize their clinic and therapy spaces to provide necessary medical and therapy services in certain cases. LIFE providers are working to ensure participants are receiving services and can receive multiple services in their home.
In March 2020, an Independent Enrollment Broker (IEB) call center in Chicago closed. Staff were quarantined for 2 weeks and required to work from home. This caused some delays, but IEB was able to maintain the same levels of enrollment as in February 2020.
The call center is now open, with some staff continuing to work from home. IEB has adapted to completing initial in-home visits and functional eligibility determinations telephonically. The outreach team continues to complete daily calls for physician certifications.
OLTL 1915(c) Waiver Appendix K
The OLTL has been working to provide flexibilities to prevent disruptions in services due to COVID-19 related issues. These flexibilities are outlined in Appendix K and have an expiration date. They pertain to CHC-MCOs, service coordinators and providers. These flexibilities have been approved from March 6, 2020 through June 30, 2020. However, the timeframe may be extended depending on the length of the declared emergency.
The OLTL is also working to provide guidance on determining if the Appendix K flexibilities apply to participants. This will be evaluated on a case-by-case basis. The revised Appendix K guidance will be released on the OLTL listservs and will include questions that can be utilized to determine eligibility.
CHC-MCOs are working to identify and prioritize services, as necessary, to ensure crucial and life-sustaining services are still being completed. Non-life-sustaining services include laundry and changing linens.
Other temporary changes outlined in Appendix K include:
- Changes to PPE. Gloves, gowns, and masks can be obtained under specialized medical equipment and supplies. These items are billable.
- Allowing spouses, legal guardians, and power of attorneys to serve as paid DCWs, as a last resort and for a brief period. This can be implemented when scheduled workers are not available due to COVID-19 and the participant’s emergency back-up plan cannot be implemented.
- Changes to retainer payments to address emergency-related issues.
- Modifications to provider qualifications.
Personal Care Homes and Assisted Living Residences
The OLTL has made temporary changes to assist personal care homes and assisted living residences with maintaining staff and providing the safest environments.
- Restrictions have been placed on visitations.
- Annual inspections have been suspended.
- Specific license regulations for personal care homes and assisted living residences have been suspended. Details on this suspension have been included in the guidance released through the OLTL listservs.
The Pennsylvania Department of Human Services, the Jewish Healthcare Foundation and several regional health systems are partnering to launch a collaborative learning and support network to offer additional resources to personal care homes and assisted living residences. These resources include online forums, educational resources, weekly webinars, and web-based clinical support.
Preadmission Screening and Resident Review (PASRR) Process Updates
Normally, the standard requirement for Preadmission Screening and Resident Review (PASRR) is to have them completed in the hospital at the same time as the clinical assessment. The 1135 waiver is allowing a 30-day delay for the assessments; however, the OLTL has decided to apply this waiver only on a case-by-case basis. If the waiver was applied to all cases, it would cause a disruption for the individuals who are determined to be inappropriate for nursing facility placement but have already been placed. Nursing facilities are already experiencing capacity pressure and this waiver would increase that. Finally, a delay may create a backlog while the COVID-19 crisis period is still active.
Below are a few of the questions from the "Third Thursday Webinar" Q&A session.
Q. How are we paying overtime?
A. The OLTL is looking to see what they can do to provide some sort of response and is currently looking for funding. At this moment, the OLTL needs more guidance before making any commitments. There is a focus in prioritization for life sustaining services.
Q. Who is eligible for retainer payments, and when are they going to occur?
A. Information on eligibility and payments can be found in the Appendix K.
Q. Will more specific guidance be provided for employment related services.
A. Currently no guidance but the OLTL is willing to consider it.
Q. How long will MCOs be doing callbacks?
A. The calls are based on participants needs. Participants should be working with MCOs to plan this out.
Q. Some agencies have been able to get PPE, and some have not. How can we get in to be prioritized?
A. It is important to let the OLTL know. They are keeping a list and sending to MCOs.
Q. Where can we get assistance in obtaining PPE? Some agencies have been able to get PPE and some haven’t; how can we get in to be prioritized?
A. If you have specific needs, you will need to reach out to OLTL. The OLTL is currently working with MCOs to provide assistance for obtaining MCOs. They are encouraging providers to look to the DOH on how PPE can be obtained more locally.
Does your facility need help with Community HealthChoices implementation? Contact Jennifer Matoushek, Senior Consultant, by calling 717-213-3130 or email JMatoushek@LW-Consult.com.