On June 25, 2020, OLTL released its plan to wind down the temporary flexibilities in place during the public health emergency (See “Transition Plan to Phase Out Temporary Changes to the Community HealthChoices 1915(c) Waiver”). Under this guidance, CHC-MCOs can begin doing needs assessments and reducing Waiver services once the participant’s county enters the green re-opening phase. As of July 3, As of July 3, all counties are in the green phase of reopening. However, as the COVID-19 response evolves, this new guidance is subject to change.
A. Person Centered Service Plans (PCSPs)
When a county enters the green phase, the CHC-MCOs may begin conducting comprehensive needs reassessments that were missed due to the public health emergency (PHE) and services can be adjusted based on the outcome of the reassessment. The CHC-MCOs must follow the established comprehensive needs assessment process prior to making any service reductions on the participant’s PCSP. Services on the PCSP that were increased or provided in a modified manner to address COVID-19 are considered temporary increases/changes. This is where further discussion will occur between OLTL and the Consumers as noted above.
B. Service Coordination
When a county enters the green phase, Service Coordinators should monitor participants and PCSPs through face-to-face contacts when possible. Monitoring of participants and PCSPs may be done remotely when risk factors are present in the participant’s home. When a county was in the red phase, this was all being done through telephone or telemedicine.
C. Initial Level of Care Assessments using the FED
When the county enters the green phase, initial level of care assessments using the FED (Functional Eligibility Determination tool) that take place in a participant’s home should be conducted face-to-face when possible. Assessments may be conducted remotely when risk factors are present in the participant’s home. Assessors must follow the guidance issued by the Independent Assessment Entity for resuming face-to-face assessments and maintain safe behavioral practices as defined by the CDC and the Department of Health when doing so (e.g. wearing appropriate PPE.)
Initial level of care assessments using the FED that take place in nursing facilities should be conducted remotely using phone or video conferencing. Assessors should follow guidance around visitation in nursing facilities that is issued by the CDC and the Department of Health.
D. Needs Assessments and Reassessments
Annual Reassessments should be conducted face-to-face when possible, unless risk factors are present in the participant’s home. Annual reassessments that were delayed beyond the 365-day requirement must be completed no later than 6 months after the county has transitioned to green.
Comprehensive Needs Reassessments should be conducted face-to-face when possible, unless risk factors are present in the participant’s home.
E. Personal Protective Equipment (PPE)
Appendix K allowed PPE such as gloves, gowns, and masks for participant to be obtained as Specialized Medical Equipment and Supplies. This flexibility will continue for the duration of the Appendix K approval regardless of the county’s status.
Respite in a licensed facility may be extended beyond 29 consecutive days without prior approval by the CHC-MCO, in order to meet the participant’s health and safety needs. This was the case when counties were in the red or yellow phase. When a county transitions to green, this flexibility continues if the need for additional Respite is a result of COVID-19. The only change is that now, prior approval by the CHC-MCO is required. This remains in effect for the duration of the Appendix K approval.
G. Personal Assistance Services
When a county enters the green phase, spouses, legal guardians, and persons with power of attorney may no longer serve as paid direct care workers. Participants will be expected to resume using their existing direct care worker or a replacement worker, if necessary.