OLTL Releases Reopening Guidance for the CHC Waiver
Office of Long Term Living (OLTL) of the Pennsylvania Department of Human Services issued guidance for Community Health Choices (CHC) Plans as the state phases out certain temporary measures adopted due to the COVID-19 emergency. In March, OLTL received permission from the federal government to temporarily change or relax certain provisions of the CHC waiver through the addition of an Appendix K to the waiver. Appendix Ks are used by states to address emergency situations affecting waivers. The changes to the CHC waiver included imposing a moratorium on service plan changes and service reductions, limiting the circumstances in which needs assessments and reassessments were conducted, and creating more flexibility to address staffing shortages and allow certain services to be provided remotely.
For the most part, OLTL’s guidance times the ending of certain Appendix K requirements with the transition to the Green Phase under Governor Wolf’s Three-Phase Reopening plan. By July 3, all Pennsylvania counties will be in the Green Phase.
Below are important highlights from OLTL’s Transition Plan to Phase Out Temporary Changes to the Community HealthChoices 1915(c) Waiver, can be read in full here.
Waiver Service Reductions: CHC-MCOs may begin conducting new assessments once the participant’s county enters the Green Phase and may reduce services based on those assessments. However, CHC-MCOs cannot reduce services, such as personal assistance services, based on assessments that are more than 90 days old. OLTL has also stated that any service reductions must be based on a face-to-face assessment.
Waiver Services Received Because of the COVID Emergency: If a participant had their services temporarily increased or changed to address COVID-related concerns, the CHC-MCO must notify the participant if their services will be reverting back to their pre-COVID level and give the participant an opportunity to appeal that decision through the grievance process.
Comprehensive Needs Assessments/Reassessments: During the Red and Yellow Phases, comprehensive needs assessments and reassessments were limited to initial assessments for new waiver enrollees and circumstances in which a participant requested an assessment, had a change in condition, or experienced a trigger event, such as a hospitalization. Moreover, assessments were permitted to be done remotely. Under the reopening guidance in counties that have transitioned to the Green Phase, there are no limits on when a needs assessment may be conducted and the expectation is that they will be conducted face-to-face when possible. Service coordinators and anyone else participating in an assessment are expected to follow CDC guidance for safe practices when engaged in in-person assessments. CHC Plans may still conduct assessments remotely when there are risk factors present in the participant’s home. However, in public meetings with advocates and consumers, OLTL has indicated a strong preference for resuming in-person assessments.
Personal Protective Equipment: OLTL’s reopening guidance continues the Appendix K flexibility for CHC-MCOs to cover PPE such as gloves, gowns, and masks for the participant as specialized medical equipment and supplies when no other source is available. Such PPE can be added to a participant’s service plan without a prescription or comprehensive needs assessment.
Services Provided by Spouses, Guardians and POAs: Spouses, legal guardians, and persons with power of attorney may no longer serve as paid caregivers once a participant’s county enters the Green Phase. OLTL had temporarily allowed these individuals to serve as paid caregivers when scheduled workers were not available due to COVID-19. Participants in Green Phase counties will now be expected to use their previous or new direct care workers or backup caregiver if necessary.
Waiver Eligibility Level of Care Assessments: CHC waiver applicants in counties in the Red and Yellow Phases received telephone assessments of their functional eligibility for the CHC waiver. In Green Phase counties, assessors are expected to resume conducting these assessments in-person where possible.
OLTL Ends Hold on CHC Plan Transfers
The Office of Long-Term Living (OLTL) is allowing CHC participants to switch their CHC-MCO again. For a brief period in May and June 2020, OLTL had imposed a hold on CHC-MCO changes. However, that freeze on plan transfers is over.
The Independent Enrollment Broker (IEB) reached out to participants whose requests to switch CHC-MCOs were held back to confirm the participants still wanted to transfer plans. Approximately 1,837 participants will be enrolled in their new CHC-MCO effective July 1. This includes participants whose requests were on hold, as well as any new transfer requests.
As a reminder, CHC Participants can request a change of their CHC Plan at any time by calling the Independent Enrollment Broker at 1-844-824-3655 (TTY: 1-833-254-0690). Participants can change their Physical HealthChoices plan by calling PA Enrollment Services at 1-800-440-3989 (TTY: 1-800-618-4225).
Department of Aging Releases Reopening Guidance for Adult Day Centers, In-Home Visits
The Pennsylvania Department of Aging (PDA) released a series of reopening plans aimed at centers and programs serving older adults. These include guidance for adult day centers and senior centers, as well as in-home visits by Area Agencies on Aging (AAAs) and Older Adult Protective Services. Summaries of each of these plans are provided below.
Adult Day Centers
The Guidance for Reopening & Operation of Older Adult Daily Living Centers provides detailed instructions for adult daily living centers regarding cleaning and infection control practices, social distancing measures, and staff screening protocols.
OLTL has shared its expectation that LIFE providers meet the expectations contained in the Adult Daily Living guidance when their LIFE center programs reopen. OLTL holds weekly meetings with each LIFE provider organization to discuss any potential issues, concerns and best practices and has requested reopening plans from each LIFE provider.
Senior Community Centers
Senior Community Centers may reopen when their county enters the Green Phase. Even when counties enter the Green Phase some centers may opt to reopen at a slower pace. The Department of Aging Senior Community Centers Guidance includes capacity limits and social distancing requirements for meal service. Centers will be required to participate in COVID-19 Case reporting.
Consumer Contact & In-Home Visits
The Guidance for Consumer Contact and Return to In-Home Visits provides direction for Area Agencies on Aging (AAAs) performing in-home, face-to-face visits for the purposes of conducting assessments and other essential activities. For counties in the Yellow Phase, AAAs will continue assessments over the phone unless there are extenuating circumstances and the consumer is comfortable with the visit. In the Green Phase, AAAs should return to in-home visits within 30 days when the consumer is comfortable with the visit. Before completing the visit, AAAs will ensure the consumer and others in the household report no signs or symptoms of illness. Note: The Department of Aging’s guidance does NOT apply to assessments by the Independent Assessment Entity (the IEB), which subcontracts with the AAAs, to determine eligibility for the CHC and OBRA waivers which are governed by OLTL’s Reopening Plans.
Older Adult Protective Services
Under the Protective Services Guidance for Older Adult Face-to-Face Visits, protective services (PS) in Yellow Phase counties will continue to conduct investigations remotely and not face-to-face, unless there are allegations of immediate or potential risk of self-neglect, serious bodily injury, serious physical injury, sexual abuse, or death. In these circumstances, a face-to-face visit may be conducted after consulting with the Department of Aging. For counties in the Green Phase, PS will conduct face-to-face visits for all investigations, unless the adult or others in the household report current symptoms or a positive test for COVID-19. In the interest of maintaining the safety of older adults and staff, PS Investigators are to follow, where applicable, Centers for Disease Control and Prevention and the Pennsylvania Department of Health guidelines for mitigating the spread of the COVID-19 virus.