CDS Operations Under COVID-19

Community Day Services (CDS) is a program of day habilitation that assists with acquisition, retention, or improvement in self-help, socialization, and adaptive skills that takes place in a non-residential setting, separate from the participant's private residence or other residential living arrangement. Activities and environments are designed to foster the acquisition of skills, appropriate behavior, greater independence, and personal choice.

CDS providers must be certified by the Bureau of Accreditation, Licensure and Certification as a CDS provider. CDS providers are able to bill 31U (site-based) and/or 31C (community-based) for services provided to individuals with intellectual and developmental disabilities.

Overarching:

Under COVID-19, our CDS providers will need to adjust their services, supports, policies, and procedures to adapt to the new safety precautions required to safely support individuals with I/DD. The Division has developed a tool to ready providers for reopening, the "Illinois CV Provider Preparedness Self-Assessment (pdf)." Providers are responsible for implementing standards and safeguards to help protect individuals' health and safety. Providers should submit their completed self-assessment tool after all sections have been marked complete to DHS.BQM@illinois.gov.  

Individuals must also decide if they would like to return to CDS programming. The Division has developed a tool to aid in discussion, however the provider is free to develop their own tool as long as it identifies benefits, risks (health, situational, and COVID-19-specific) and mitigation of risks for each individual. All individuals must be formally assessed prior to returning to their CDS program. These assessments must be saved in the individual's file for review by surveyors.

The State has developed the "Illinois Risk Benefit Discussion Tool (pdf)" as a resource for individuals, their families/guardians, and their provider to have important discussions in weighing the benefits and risks of participation. Providers can use this instead of their own developed tool. If a provider chooses to use their own tool, they should consider this tool (pdf) as the floor of what would be required in their own document.

In addition, individuals will continue to work with their Independent Service Coordination (ISC) agencies to develop a Personal Plan that best meets their needs and identifies a provider to implement the plan.

The Division wants to clarify that common practice has often been for individuals to start and end their day at a CDS site, but providers are not required by rule or policy to bring individuals to the main CDS building, if it makes more sense to start directly in the community. We hope this provides additional flexibility.

There is a fiscal year maximum of 1,100 hours for any combination of day programs or supported employment and the monthly maximum is 115 hours for any combination of day programs. These include: Community Day Services (31U, 31C), Adult Day Services (35U), Supported Employment (39U, 39G), and At Home Day Program (37U).

Helpful Links for Individuals and Providers:

People who need to take extra precautions:

https://www.cdc.gov/coronavirus/2019-ncov/need-extra-precautions/index.html

Disability and Health:

https://www.dph.illinois.gov/topics-services/life-stages-populations/disability-health-program

General Health Screening:

• COVID-19 symptoms include cough, shortness of breath or difficulty breathing, fever of 100.4 degrees or above, chills, muscle pain, headache, sore throat, new loss of taste or smell, or other CDC-identified symptoms. For the most up-to-date information from the CDC: https://www.cdc.gov/coronavirus/2019-ncov/symptoms-testing/symptoms.html
• No staff or individual is able to attend CDS if they are COVID-19 positive, have symptoms of COVID-19 or have had a recent exposure to someone who is COVID-19 positive. Individuals who were COVID-19 positive should receive medical clearance from a medical doctor prior to returning.
• Providers should adopt a screening process and screen all staff and individuals prior to transport and/or participation in programming.
• Sick or symptomatic staff/individuals should be encouraged to seek testing for COVID-19 at a State or local testing center, healthcare center, or other testing locations.
• Providers must deep clean their facility and transport if exposure to COVID-19 has occurred. No staff or individuals should use the facility or transport until this has occurred.
• Staff and individuals should wear face coverings over their nose and mouth during CDS programming both on and off the CDS site. Exceptions may be made where accommodations are appropriate. Please see IDHR's guidance:  https://www2.illinois.gov/dhr/Documents/IDHR_FAQ_for_Businesses_Concerning_Use_of_Face-Coverings_During_COVID-19_Ver_2020511b%20copy.pdf

• Social distance of at least 6 feet should be maintained between individuals who do not live together.
• Frequent hand washing by staff and individuals, and an adequate supply of soap/paper towels and/or disinfectant/hand sanitizer should be available.
  • Providers should provide hand washing capability or sanitizer to staff and individuals.
  • Individuals should be supported to properly wash their hands at regular intervals.
• Additional trash receptacles may be needed and/or repositioned to collect used paper towels or PPE.

Self-Assessment:

DDD is providing guidance through a self-assessment approach using a State-developed tool, "Illinois CV Provider Preparedness Self-Assessment (pdf)," to assist providers in planning and implementing day services in order to ensure:

• an organization-wide systematic implementation
• support for individuals' needs and choice
• the safety of individuals, families, caregivers, and provider staff
• proper training for staff to support individuals as they phase back into services

Providers should maintain their self-assessment and finalized policies and make them accessible to staff, individuals, families, and stakeholders. The Bureau of Accreditation, Licensure and Certification, as well as the Bureau of Quality Management may request to review.

The provider should develop, and all staff should complete, health and safety training related to COVID-19 when initially returning to work. In addition, the provider should develop materials that will help ease the transition back for individuals. This would include new protocols, screening processes, and any COVID-19-related policies, as outlined in the "Illinois CV Provider Preparedness Self-Assessment."

The "Illinois CV Provider Preparedness Self-Assessment," once completed, should be submitted to DHS.BQM@illinois.gov .

Re-Opening CDS:

DDD will pay Reinvention Payments for July and August 2020 for CDS providers to remain closed. For those providers that would like to open prior to September 1, 2020. the Division will allow a soft reopening process beginning, August 1, 2020. Providers who wish to reopen before September 1, but no earlier than August 1 must (i) complete the Illinois CV Provider Preparedness Self-Assessment (pdf), (ii) complete a Risk Benefit assessment (pdf)of each potentially participating individual, with the DDD or a comparable tool, prior to that individual participating and (iii) provide an operational plan for meeting soft opening guidelines. Providers opening prior to September 1, but no earlier than August 1, should reopen with a maximum of 25 individuals or 25% room capacity, whichever is smaller. This is a maximum and providers may and are encouraged to start more gradually. Providers can increase capacity after at least 2 weeks of steady operations.

The benefits of a soft reopening are as follows:

• Providers are able to assess the operational feasibility of their proposed policies
• Providers are able to trouble shoot issues and identify problems that require resolution
• Providers can use it as an opportunity to transition individuals that may need more time to adapt to new processes and might need more support and guidance (and will have more staff support)

DDD will offset the difference between billable hours and the reinvention payment for the month of August.

Facilities:

• Signage should be posted, reminding individuals and staff to wash hands and maintain appropriate social distancing.
• Post the maximum number of persons that can be accommodated in any designated space or room.
• Providers should install visual cues, demonstrating a distance of 6 feet.
  • Tape can be put on the floor, indicating 6 feet of distancing, especially in areas where lines form (bathrooms, copy machines, etc.).
  • Signs can be put on walls, demonstrating how far apart individuals should be.
  • Visit the Illinois Department of Commerce and Economic Opportunity for more resources.
• Use of arrows or directional symbols taped on the floor can indicate the direction of traffic.
• Staff and individuals should wear face coverings in line with IDHR accommodations.
• Non-professional capacity visitation should be discouraged. All allowed visitors should follow the same guidance as staff and individuals, including screening and the donning of a face covering.
• Avoid crowding on ingress and egress and, where possible, have separate entrances and exits.

Disinfecting/Cleaning Procedures:

• High touch surfaces should be cleaned frequently during the day (every 2 hours) including, but not limited to, door handles, light switches and vending machines.
• Water fountains and communal kitchen utensils should be cleaned frequently and not used if at all possible (e.g. coffee makers, toasters, etc.). Consider utilizing a designated staff person to serve or distribute shared use items in a cafeteria or break room.
• The entire facility, including equipment and furniture, must be cleaned each night or prior to a new group of individuals utilizing a space.
• Sanitize items used in activity between users: game pieces, craft tools, etc.
• Visit the CDC for more resources and disinfecting protocols:  https://www.cdc.gov/coronavirus/2019-ncov/community/disinfecting-building-facility.html

Programming and Support:

• For the September 1 open, for indoor facilities, maximum occupancy is 50 or 50% of room capacity, whichever is smaller. This is a maximum and providers may and are encouraged to start more gradually.
  • Within each room, individuals should be able to adequately social distance (6 feet separation). If social distancing is not feasible, groups should be limited to people within the same household or activity should be suspended.
• Providers should maintain groups of 10 individuals (including necessary staff) or fewer. These individuals should participate in activities together throughout the day, preferably in the same space. Groups should be static, with no mixing of individuals or staff between groups.
• Multiple groups in one facility are permitted as long as the following occurs:
  • 30 feet of distancing should be maintained between groups or there are distinct room(s) or physical barriers between each group.
• Social distancing should be maintained in bathrooms. 
• Lunch breaks and/or snacks should be facilitated so that groups eat together in their programming space. Alternatively, groups could use a designated lunch space with appropriate disinfection prior to a new group using the space.
  • Large lunch gatherings are discouraged.
  • Distancing of all individuals while eating should be maintained while masks are off to eat.
  • Sharing food or refreshments is prohibited for individuals and/or staff.
• When possible and appropriate, programming should happen in the community or outdoors. All social distancing and masking guidelines should be maintained (with the exception of accommodations as appropriate).
• Avoid activities that involve multiple residents handling the same object (e.g., ball toss).
• Avoid vocal performances or sing-alongs; instrumentation should not include wind instruments.
• Providers should be prepared to explain policies and procedures, including safety measures and screening processes, to individuals using developmentally-appropriate language that the individual can understand. The use of social stories can assist in this process.
• In the event a provider becomes aware of a positive case of staff or individual in their CDS program they should notify the Illinois Department of Public Health, as well as impacted individuals, families and partnering providers.
• Providers must deep clean their facility and transport if exposure to COVID-19 has occurred. No staff or individuals should use the facility or transport until this has occurred.

Transportation Guidance:

For CDS programs that are providing individuals with transportation:

• Providers should ensure every individual receives a screening for COVID-19 symptoms BEFORE being allowed to enter a vehicle carrying other people to a CDS site. This may be done by the driver, residential provider, family member, or other designated staff member.
• Providers should provide hand sanitizer at the entrance of the vehicle. All riders should wash or sanitize hands prior to boarding or exiting the vehicle.
• The interior of each vehicle should be sanitized before and after use by individuals and staff.
• Staff, driver(s), and individuals should wear face coverings when in the vehicle, in line with IDHR accommodations.
• Procedures must support staff to maintain social distancing when loading and unloading.
• Individuals should maintain social distance from non-household members while in the vehicle.
• Providers should ensure individuals coming from a group residence or congregate setting are transported together, as appropriate.
• Individuals should sit in staggered rows (one individual per seat, per row).
• Individuals should sit one to a row unless sitting with additional household members.
• If a rider in the vehicle is identified as being COVID-19 positive, CDC cleaning and disinfecting protocol should be performed as soon after the confirmation, as practical, and before the vehicle is put back in service.
• Other riders who were transported in a vehicle with another rider who tested positive for COVID-19 should not participate in CDS until symptom free according to the most recent IDPH guidance.

Billing:

• CDS programs must be open for a minimum of 5 hours per day, any day they are open. Individuals may choose to attend less than 5 hours. CDS providers can bill for a maximum of 7 hours per day.  Note: if multiple day programs or supported employment is used, there must be Implementation Strategies that define exactly the hours billed for each type of service to ensure the 1,100 hours is divided appropriately. The ISC is responsible for ensuring all services are reflected and itemized appropriately.
• CDS programs can only bill for hours when the individual is actively participating in day program activities.
• CDS providers have the option to bill CDS under 31U or 31C, or any combination during each day, depending on the support provided.
  • 31U billing will be used for CDS provided in a Site-Based Setting.
  • 31C billing will be used for CDS provided at a community location.
• CDS Providers may transport an individual(s) directly from their residence to a community activity. Travel time from the individual's residence to the first community location is not authorized to be billed but all travel time between community locations is allowed to be billed.

This guidance should not be construed as legal advice, as a provider you should consult your legal counsel.

Effective Date:

Upon Final Posting