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Illinois Department of Human ServicesJB Pritzker, Governor · Grace B. Hou, Secretary
Q - If the incoming ISC would hire staff employed at the current agency do new employee background checks, drug screens and fingerprints need to be completed?
A - Staff employed at one ISC and then hired by another ISC are treated as "new" employees for the purposes of the background checks and training with the following exceptions: 1) If a Health Care Worker Registry (HCWR) fingerprinting was completed and results available this does not need to be completed again; 2) If Qualified Intellectual Disability Professional (QIDP) training was previously completed, it does not have to be repeated. ISC staff who are transferring to a new employer who need such checks may have them initiated no sooner than 30 days prior to beginning employment and no later than the 1st day in paid status at the new employer.
Q - If an ISC has a 1999 letter from the Division identifying a staff can work as a service coordinator even though that person does not meet the requirements of a Qualified Intellectual Disabilities Professional (QIDP) can the incoming ISC hire that person to provide ISC duties and responsibilities?
A - No, the incoming ISC cannot hire that person to perform case management duties and responsibilities. Developmental Disabilities services in Illinois has changed since the letter was sent to ISCs in 1999. Most notably, there are significantly higher expectations for conflict-free case management and person-centered planning for those participating in Medicaid Home and Community Based Services waivers. The Federal expectations are clear - case management (including eligibility determination, planning, linkage to qualified providers, and monitoring of plan implementation) must be done by a staff person who meets the requirements of a Qualified Intellectual Disabilities Professional (QIDP). Although the communication from DHS in September 1999 did allow staff who did not meet the QIDP requirements to continue to assist with some duties at the ISC agencies, that communication did not "grandfather" those employees into the QIDP role nor did it result in those employees being added to the QIDP database maintained by the Division. Therefore, they may not serve in any role that requires the staff person to meet QIDP requirements - PAS, Bogard, or ISSA - even if their work is reviewed and signed by another staff person who is QIDP. (Please see Required Experience, Job & Educational Requirements for QIDPs which may be found at http://www.dhs.state.il.us/page.aspx?item=48211. The decision to hire or retain non-QIDPs rests with the leadership of each ISC. If those staff continue to be employed, ISC administration will need to ensure that their duties do not include the functions of PAS, Bogard or ISSA.
Q - Will ISC staff hired from the current ISC agency have to be retrained on OIG, DCFS, etc. or can these certificates essentially be transferred?
A - Training information within Attachment A requires retraining in Rule 50 at the time of hire and before any direct contact with persons receiving services. Although Rule 50 expectations do not change from employer to employer, the local process for alerting supervisory staff, etc. may be different. Therefore, the person should be retrained. A specific course is not required so the retraining may be a brief refresher on Rule 50 requirements plus additional information about any expectations specific to the new employer. The same is true for DCFS mandated reporter training and APS training. Agency specific requirements need to be addressed with the new employee. Following is additional information from Section VIII Part N of Attachment A: ISC Providers must ensure all employees successfully complete DHS OIG approved 59 Ill. Adm. Code 50 training at the time of hire (before the employee assumes any regular duties or responsibilities of the position) and a biennial (every two years) refresher training course approved by DHS OIG pursuant to Rule 50.20 (d)(2); are trained at the time of hire (before the employee assumes any regular duties or responsibilities of the position) and biennially (every two years) about reporting requirements for DCFS; and are trained at the time of hire (before the employee assumes any regular duties or responsibilities of the position) and biennially (every two years) regarding Adult Protective Services.
Q - Do ISC staff hired from the current ISC agency have to complete the 40-hour QIDP training requirement?
A - No. There is no expectation that ISC staff repeat the 40-hour QIDP training if they have already been trained. It is suggested that the new employer use the QIDP competency checklist to assess skills and identify areas that may need refresher.
Q - What if the incoming ISC is supplying employment information to the current ISC Executive Director but the information is not passed down to employees? Is there any support DHS can provide incoming ISCs in this situation?
A - It is in the best interest of the people served to continue services with familiar staff. Also, for continuity of care the current ISC staff providing the services should be hired by the incoming ISC. Communicating this information to current ISC staff is very important for the people served.
Q - How and when will the Division transfer CIRAS cases from one ISC to another?
A - The transfer of cases from the current ISC to the incoming ISC is automatic based on ROCS billing. DDD is working with MIS to transfer cases in ROCS from one ISC to another at the end of June 2019. For any open cases on June 30, 2019, DDD staff will change the designated ISC and notify that ISC of the change.
Q - How should the incoming ISC register new staff (from the current ISC) to CIRAS?
A - ISC staff that are changing employers would still have access to CIRAS by using their Illinois.gov email address. However, after July 1st, the incoming ISC agency should contact Mike.Blazis@illinois.gov with a list of the new employees and their new ISC agency email address in order to ensure they have access to the correct documents.
Q - What is the timeframe for new staff (not currently working as an ISC agent) to become enrolled in CIRAS?
A - Enrollment in CIRAS is quick, usually the same day that the request is received but definitely within a day or two. The incoming ISC agencies should register new employees as soon as possible. There is always at least one person at the ISC agency who has access to the CIRAS system. In cases where the new ISC agent can not yet directly access the CIRAS data, a co-worker with access could assist.
Q - What is the DDD's expectation with existing equipment?
A - Any equipment that cost less than $5,000 can be kept (or given to current staff, given to the incoming ISC or given away)
Q - When determining if equipment purchased costing $5,000 or more with State resources needs to be returned, is the value based on the original cost or the depreciated value?
A - The current ISC needs to identify what was purchased with DHS/DDD funds costing $5,000 or more in FY19 only. Any equipment purchased earlier than FY18 does not need to be returned to the State. Equipment purchased in another fiscal year is not applicable to the return policy.
Q - How and where should a current ISC return equipment costing more than $5,000 to the State?
A - If there is equipment that needs to be returned to the State, let the DDD ISC Transition Lead staff know and a decision will be made as to how and when the equipment will be returned.
Q - How and when will Birdseye or the equivalent data be transferred to the incoming ISC agency?
A - Data from one ISC to another ISC will not be transferred but copied. The current ISC will not lose any data. The Division has already directed Provisio to begin exporting data from ISC agencies that are scheduled to transfer services to another ISC effective July 1, 2019. Provisio began conducting this data migration in phases April 30, 2019 and will continue through Jun 30, 2019. This will not affect the agencies current operations or ability to provide services. These data transfers are required in order to allow sufficient time to ensure data integrity and ensure a smooth transition of services. Recently, questions have come up about the legality of sharing data with Provisio. The Division has consulted the DHS General Counsel's office and has been assured that sufficient legal authority for the transfer of this data exists within the ISC Contracts. For details, see Article XII - Maintenance and Accessibility of Records; Monitoring Section 12.2, Article XXX - Work Product Section 30.1, and Article XXXI - Post-Termination/Non-Renewal Section 31.1.
Q - How long should client files be retained?
A - Client files must be maintained for 6 years once a person has terminated services (moved out of state, elected to leave services or passed away.)
Q - What should ISC agencies do with files of people who are no longer receiving services?
A - DHS is accepting all files of people who are inactive (closed files) and that are less than 6 years old. DDD is working with DHS and will give details to the those ISC agencies with records to be stored. If an ISC has files closed files that are older than 6 years old, they are responsible for destroying those records.
Q - Do closed files have to be separated by County?
A - No
Q - When can active files be exchanged?
A - As soon as possible before June 30th. This will depend on when the incoming ISC has office space available for the records.
Q - Is it acceptable practice/HIPAA compliant to have ISC client files in locked file cabinets in staff homes?
A - Yes, records need to secured in a locked cabinet or locked room.
Q - How long should fiscal records (vouchers, billing, other financial records) be retained?
A - Fiscal records must be maintained according to IRS requirements.
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