Good Afternoon,
CHANGES EFFECTIVE 9/1/20
As a reminder, the ICF/DD and Children's Group Home increase and CDS Reinvention payments will end on 8/31/20. The Division is pleased that we were able to provide close to 6 months of retainer payments and increased support to our providers, as well as introducing additional service and policy flexibilities. We will continue to monitor the service system and adjust as we are able.
REMITTANCE REPORTS ISSUE
The Division was informed this morning by the DHS Department of Innovation and Technology (DoIT) that MOBIUS Remittance Reports usually available every Friday morning did not generate last night as expected. Providers who did billing this week will not be able to find these reports until they are generated in MOBIUS. DoIT is working on fixing the problem but repair time is not currently known. The Division will inform providers when we are informed the reports are available through MOBIUS. We apologize for the issue.
COMMUNITY DAY SERVICES SURVEY
Next week the Division will be releasing a survey for providers of CDS programs. We will need a survey completed for EACH site that you operate (or operated). This survey will help us understand the CDS operations post-reopening. Ongoing, we will be collecting data on service capacity and closure to closely monitor the CDS service system.
CDS WEBINAR QUESTIONS
Thanks to all who attended the Community Day Services webinar on August 21st. There were a few unanswered questions that I will address below. In the future, we plan to have someone designated to respond to questions in the chat during the webinar.
First, I wanted to state there were a number of specific questions in the chat in regard to provider operations in response to our guidance. Providers will need to use the Division's guidance and adapt as needed for their operations. This should be outlined and documented in the Provider Self-Assessment you submit to BQM. Also, if you are in doubt about something you are interested in implementing, I would suggest reaching out to the Division to discuss.
- Historically we receive a full month of payment if we serve someone in an ICF/DD for 1 day in the month. Is this still true? Is it also true if we serve them at their site? How many hours per day do we need to provide?
- The Division is working on billing and payment guidance for CDS providers serving ICF/DD residents. With that being said, we would continue to expect a full 5 hours of service either at the site of the CDS or on-site at the ICF/DD.
- What if the individual wants to watch TV as part of 37U programming? Will this choice be honored?
- No, 37U is specifically a day habilitation program with structured activities. Watching television is certainly a choice for individuals but the provider cannot bill this activity as a habilitation program. Please see the published Information Bulletin on 37U: https://www.dhs.state.il.us/page.aspx?item=125456
- Can someone explain to me why there is no funding for continued reinvention payments. When we would be under normal circumstances billing for those same amounts?
- If a HBS resident is no longer attending a CDS program then they are, often, using this funding for other services. If CILA clients are choosing to use the funding that would go to a CDS to pay for At-Home Day (37U) services, then the money is going to that service. As a result, these funds are being reallocated to fund other activities and programs. There may be cases where an individual is not re-allocating the funds but that would be a case by case issue and not a system wide occurrence. Finally, the reinvention payments are solely state funded at this point. We do not receive federal match on these services.
- What flexibility do we have in billing 37U and 31U/31C? Can weekend days be included?
- For 31U/31C, yes, weekends can be included. For 37U, no, as weekends are already covered in the CILA rate model.
- Can individuals from facilities who have already had COVID-19 come back and not be counted in our percentages since they have already had COVID?
- Can 56U providers resume in person services in a CDS setting?
- 56U providers can provide clinical services at the discretion of the individual and providers per the Information Bulletin (https://www.dhs.state.il.us/page.aspx?item=125150). There should be a conversation that discusses the benefits and the risks of providing these services in person.
VIRTUAL DAY SERVICES NEXT STEPS
I want to thank everyone who sent me positive feedback about the Virtual Day Service option we've requested under our Appendix K. While we wait on CMS approval, we are moving forward with the behind the scenes support to make this happen (ROCS, policy, etc.). We will release more information after CMS approval.
MITIGATION GUIDANCE
As you may be aware, IDPH announced that Region 7 is entering into mitigations due to an increase in COVID cases. You can find all IDPH community-based mitigation guidance here: https://www.dph.illinois.gov/regionmetrics?regionID=1 We have, again, received clarification from IDPH that CDS providers in Regions 4 and 7 are not required to make changes to their operations in response to the mitigations announced. However, community-based guidance is different than guidance for our LTC facilities, which specifically, and exclusively, impacts ICF/DDs. IDPH Siren released on 8/24 notes:
"Starting Wednesday, August 26, Illinois COVID Region 7 is subject to mitigation measures (Tier 1) due to high test positivity rates in the region. Note the following points, based on IDPH's reopening guidance that took effect on August 14: Reopening Guidance
- Any LTC facilities in Region 7 that have already advanced to CMS Phase 3 must suspend indoor visitation and off-site outings. Meanwhile, outdoor visitation may continue. Indoor visitation and off-site outings can be resumed 14 days after tiered mitigation for the region is lifted.
- Any LTC facilities in Region 7 that have not yet advanced to CMS Phase 3 are not eligible to advance to CMS Phase 3 until 14 days after tiered mitigation in the region is lifted. Specifically, that means that any plans to begin indoor visitation and off-site outings in association with phase advancement must be postponed until that time. Meanwhile, outdoor visitation may continue."
As a result, ICF/DD residents in Region 7, like Region 4, will not be allowed to attend CDS programs at this time. We have, however, received notification that providers are able to send people to an ICF/DD to provide CDS.
Thank you for all you do!
Warmly,
Allison