COVID 19 Home Based Support (HBS) & Fee-for-Service Billing, Agency and Consumer Guidance

Illinois Department of Human Services

Division of Developmental Disabilities

Information Bulletin

DD.20.004

Purpose:

The Illinois Department of Human Services (IDHS) Division of Developmental Disabilities (DDD) is committed to protecting individuals with developmental disabilities in Illinois during the COVID 19 Pandemic. The best way to prevent illness is to avoid exposure. This communication is intended to provide guidance for the Home Based Support program, as well as guidance for providers who are authorized to provide Behavior Intervention, Individual/Group Counseling, Individual/Group Therapy as well as to providers of Physical, Occupational and Speech therapy, Self-Directed Assistance, Temporary Assistance/53C and Bogard Specialized Services.

For more information:

Jim Eddings at 217.557.6335 or Jim.Eddings@Illinois.Gov


Overarching:

The DDD is working with all levels of government including sister agencies and our partner providers during these unprecedented times. The DDD's utmost concern is for the health, safety and wellbeing of the people we serve and the staff who support the people we serve. To lessen the spread of the coronavirus, we have asked all community day services and other day programs to temporarily close during this time. In addition, Independent Service Coordination Agencies (ISCs) will be providing remote support.


Home Based Support:

  1. If part of the monthly allotment is used to purchase Community Day Services (CDS) these funds can now be redirected and used to purchase other services, such as Personal Support Workers (PSW).
  2. If you would like a service that is not currently reflected in your Personal Plan & Implementation Strategy you should contact your ISC Agency and provider who will reflect these changes. Verbal or email approvals are acceptable.
  3. Service Agreements should be adjusted accordingly and account for all services.
  4. Obtain required signatures when possible; verbal or email approvals are acceptable during this time.
  5. Providers and individuals may backdate authorizations in Service Agreements to March 2020.
  6. If an HBS participant's primary caregiver, who is not paid as a PSW, becomes sick a request for Temporary Assistance (53C) funds can be submitted.  The 53C service requires Prior Approval from the Division. The Prior Approval Request should be developed and submitted through the ISC agency.  Temporary Assistance (53C) will allow participants to hire additional persons to assist with providing essential care. It provides an additional $2,000/month for two consecutive months and is above the monthly allotment. Temporary Assistance is not available for caregiver absences for vacations, educational or employment related reasons or other non-emergency reasons.
  7. HBS participants should consider expanding their pool of PSWs either through an Agency or by enrolling new staff with their fiscal intermediary. It is best to begin the enrollment process as soon as possible.
  8. PSWs may support a waiver participant in the hospital and be reimbursed, pending hospital approval to accompany the individual..
  9. For the individuals who are enrolled in the Adult HBS waiver but are still in school, DDD will adjust the monthly allotment from 2 times the Supplemental Security Income (SSI) amount ($1,566) to 3 times the SSI amount ($2,349) during this period. This change will be retroactive to the month of March 2020 to address the onset of this crisis period. Service agreements must be updated accordingly. This change will increase your overall annual allotment.


Children Home Based Support (Additional Guidance):

  • For families enrolled in Children's HBS, DDD will adjust the monthly allotment from 2 times the SSI a/mount ($1,566) to 3 times the SSI amount ($2,349) during this period.  This change will be retroactive to March 2020. Service agreements must be updated accordingly.
  • The flexible spending amount for the Children's HBS program will remain at a monthly maximum of $3,132.
  • This temporary increase in Children's HBS will assist families in providing care during the normal school day while schools are temporarily closed due to crisis period.
  • Parents or responsible guardian will be allowed to be a Personal Support Worker (PSW) for their child as long as they are not the employer of record through the crisis period.


Self-Directed Assistance Guidance:

  • The DDD expects Self-Directed Assistants (SDA), if applicable, will continue to provide remote support for individuals and families via electronic and/or phone & video communications.
  • As all services can be provided remotely, there will be no additional payment or subsidy for this service.
  • All Service Agreements must be updated to accommodate any change in total monthly expenditures. Service Agreements must be updated for the month of March if budgets changed based on CDS closures or increased PSW hours.


Individual Controlled Personal Support Worker Guidance:

  • The DDD has worked with ACES$ to streamline the documentation process to enroll new Employers and PSWs. There will be a shorter "emergency enrollment packet" used during the COVID 19 crisis period. The full-length versions of the packets will have to be completed once the crisis period is over.
  • Individual controlled PSWs will not have to wait for fingerprint results to be completed to start work. The individual controlled PSW can start working once their paperwork has been entered into ACES$'s system. ACES$ has reported this should take 2-3 business days depending on IMPACT Enrollment.
  • PSWs will have 30 days from date of hire to complete fingerprints.
  • Individual controlled PSWs will be terminated immediately if there is a positive hit on their background checks or fingerprints.


Agency Based Personal Support Worker Guidance:

  • Agency Based Personal Support Workers (PSW) who normally work in HBS settings should continue to do so at the discretion of the families. They are essential workers and are allowed to continue to work under the Shelter in Place/Stay at Home Order.
  • We suggest families implement a health screening protocol prior to their PSW coming to their home. Refer to Illinois Department of Public Health Guidelines for more information. http://www.dph.illinois.gov/topics-services/diseases-and-conditions/diseases-a-z-list/coronavirus/personal-guidance-and-testing
  • In the event a family member is not interested in having their Agency Based PSW work with them, we suggest the Agency Based PSW be redeployed to a residential setting. In general, we suggest that staff not being utilized in their normal work assignment be redeployed to other areas of the organization where support is needed. Redeployed Agency Based PSWs to assist or staff other areas of the agency should not bill 55D.
  • In the event an Agency Based PSW chooses not to provide support, either in the family home or another HBS consumer, DDD will not reimburse, or subsidize, for the services that could have been provided.
  • In the event there is no opportunity for service delivery of an Agency Based PSW and no opportunity for reassignment, the Division will calculate the 6-month average of each Agency Based PSWs billing and pay the difference between the average and the billing during this crisis period.
  • Providers will need to submit documentation to the Division showing they were unable to provide work to the Agency Based PSW.


Supports that are Fee-for-Service:

  • A number of services under the waiver are provided on a fee-for-service basis. In general, we direct all fee-for-service providers to continue to provide services remotely via electronic, phone and/or video communications. These will be billable through applicable DDD billing codes.
  • Generally, in the event a provider of fee-for-service services chooses not to provide the service remotely DDD will not reimburse, or subsidize, for the services that could have been provided except in the exceptions noted below.
  • Also, DDD encourages providers to redeploy staff members to critical areas within their organization, in particular as DSPs in residential environments. Modified training requirements are forthcoming.


Behavior Intervention & Treatment (Level 1 & Level 2):

  • Behavior Intervention & Treatment services are beneficial and, in some instances, vital to the individual in need of these services in maintaining the health and well-being of the individual.
  • In order to be reimbursed, services are required to be provided remotely via means of electronic, phone, and/or video communication to individuals, families and agency staff.
  • Behavior Intervention & Treatment services provided remotely via electronic, phone, and/or video communications are billable through the applicable DDD billing code.
  • There will be no additional payment or subsidy for providers that choose not to provide behavior services remotely as this is an essential service that can be provided by remote support.


Occupational and Speech & Language Therapy, Counseling and/or Therapy for Group and/or Individual:

  • Therapeutic services are beneficial, and in some instances vital, to the individual in need of these services and maintaining the health and well-being of the individual.
  • Therapeutic services provided remotely via electronic, by phone, and/or video communications are billable through the applicable DDD billing code.
  • In the event a provider of fee-for-service services chooses not to provide the service remotely, DDD will not reimburse or subsidize for the services that could have been provided.


Supported Employment Guidance (39U/39G only):

  • Prior to and after the Shelter in Place/Stay at Home Order, the Employment staff should provide supports to individuals in their jobs, unless the individual has taken a leave.
  • The Division expects providers to redeploy waiver funded employment staff when appropriate as DSPs to supplement residential site staffing shortages during the crisis period. Providers should not bill 39U or 39G for redeployed employment staff.
  • In the event there is no opportunity for service delivery of supported employment, the Division will calculate the 6-month average of each provider's billing and pay the difference between the average and billing during this crisis period.


Bogard Specialized Services:

  • The Division expects that Bogard service providers will continue to provide remote support electronically, by phone, and/or video communications to nursing home residents.
  • Bogard Specialized Services provided remotely via electronic, phone and/or video communications are billable through the applicable DDD billing code.
  • In the event there is no opportunity for service delivery of fee-for-service programs, the Division will calculate the 6-month average of each provider's billing and pay the difference between the average and billing during this crisis period.
  • Providers will need to submit documentation to the Division showing they were unable to provide the service remotely.


Finally, in the event a Provider receives unemployment compensation, while also receiving payment from the State, for the same services, please to submit documentation of the amount of unemployment compensation received to the Division.


Resources:

Illinois Department of Public Health at www.idph.illinois.gov

Centers for Disease Control at www.Cdc.gov

Administration for Community Living at https://acl.gov/COVID-19

Self-Advocacy Resource and Technical Assistance Center at www.Selfadvocacyinfo.org


The information contained herein should not be considered a substitute for the appropriate official statutes, rules, regulations, or the advice of legal counsel.


Effective Date:

Upon Final Posting