PHLP continues to hear from Community HealthChoices (CHC) participants whose plans are attempting to reduce or deny personal assistance services (PAS) based on comprehensive needs assessments that were completed by telephone. PHLP wants to remind participants and advocates of guidance from the Office of Long-Term Living (OLTL) that states these assessments should be completed in-person, if possible.
The CHC Agreement requires CHC plans to complete an in-person comprehensive needs assessment at least once a year and any time there is a triggering event, such as a hospitalization or a change in caregiver status. OLTL temporarily waived this face-to-face requirement during the COVID-19 pandemic and allowed CHC plans to complete these assessments remotely using phone or video conferencing. However, in July 2020, OLTL issued updated guidance for counties in the green phase, including this language:
“Annual Reassessments, including the needs assessment, should be conducted face-to-face when possible. Reassessments may be conducted remotely when risk factors may be present in the participant’s home. Service Coordinators should maintain safe behavioral practices as defined by the CDC and the Department of Health when doing so.”
Despite this update, some service coordinators are still telling participants that assessments are only being done telephonically due to the pandemic, without offering participants the option of an in-person assessment. PHLP is concerned that some of these telephone assessments miss key information, since the service coordinator does not have the opportunity to observe the participant and their environment. Furthermore, the widespread availability of highly effective COVID vaccines has dramatically reduced the risk of in-person assessments. The CDC recently updated guidance stating that indoor activities pose minimal risk for fully vaccinated people, and that fully vaccinated people have a reduced risk of transmitting COVID-19 even to unvaccinated people.
PHLP reminds CHC participants and their advocates that service coordinators should normally be scheduling assessments in-person, unless the participant requests the telephone assessment or there are specific risk factors that make the in-person meeting unsafe. These risk factors include an unvaccinated participant or service coordinator as well as a service coordinator, participant, or household member testing positive for COVID or exhibiting COVID symptoms. Telephonic assessments should be the exception, not the norm. PHLP wants to hear from participants whose service coordinators either refused to conduct an in-person assessment or never offered an in-person assessment. You are encouraged to contact PHLP’s Helpline at 1-800-274-3258 or firstname.lastname@example.org.