Update - 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), 31C (community-based) and/or 31V (virtual) for services provided to individuals with intellectual and developmental disabilities.

Community Day Service facilities have been deemed congregate facilities by the Illinois Department of Public Health, therefore these facilities are required to follow guidance from the Department of Commerce and Economic Opportunity (DCEO).

This Information Bulletin replaces DD.20.012

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." Providers are responsible for implementing standards and safeguards to help protect individuals' health and safety. For providers who haven't already completed the self-assessment, they 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 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 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. When conducting community-based services, a provider is allowed to begin services at the community location. We hope this provides additional flexibility.

There is a current 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), Virtual Day Services (31V), Adult Day Services (35U), Supported Employment (39U, 39G), and At Home Day Program (37U).

Self-Assessment:

CDS providers re-opening after extended closure should complete a self-assessment using the State-developed tool, "Illinois CV Provider Preparedness Self-Assessment," to ensure:

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

All CDS 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.

Helpful Links for Individuals and Providers:

People who need to take extra precautions:

Disability and Health

CDC Guidance on Adult Day Programs:

CDC Communications Resource Page:

General Health Screening:

• COVID-19 symptoms include, but are not limited to, cough, shortness of breath or difficulty breathing, fever of 100.0 degrees or above, chills, muscle pain, headache, sore throat, new loss of taste or smell, or other CDC-identified symptoms. The most up-to-date information from the CDC. Staff who are symptomatic or test positive for COVID-19 should be directed to remain at home or sent home immediately, should they become ill at the CDS site, per IDPH and CDC guidelines.
• Symptomatic staff must be tested for COVID-19 and symptomatic individuals should be encouraged to be tested for COVID-19.
• Staff or individuals should not return to CDS until all of the following are true:
  • They have had no fever for at least 24 hours without the use of medicine that reduces fever.
  • Symptoms, such as cough or shortness of breath, and overall condition have improved.
  • At least 10 days have passed since symptoms first appeared.
• Providers should adopt a screening process and screen all staff and individuals prior to transport and/or participation in programming.
• Asymptomatic COVID-19 positive staff may return to work after at least 10 days have passed since the date of their positive test.
• Asymptomatic COVID-19 positive individuals may return to CDS activities after at least 10 days have passed since the date of their positive test.
• 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 alcohol-based hand 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.

Vaccination Status:

• In order to determine if a person is fully vaccinated, providers may ask staff and individuals to share their proof of vaccination. However, staff and/or individuals are not required to share their proof of vaccination.
• If vaccination status cannot be determined, the provider must follow all recommended infection prevention and control practices including maintaining 6 feet of physical distancing.
• Services cannot be denied based on vaccination status.

Masking:

• When conducting CDS activities at a site based (31U) setting, staff and individuals should wear face coverings over their nose and mouth during CDS programming both on and off the CDS site regardless of vaccination status. Please continue to follow closely the CDC guidance for masking.
• Face masks with exhalation valves or vents are not recommended for source control because they do not prevent the user from spreading respiratory secretions when they breathe, talk, sneeze, or cough.
• Staff and individuals who have a condition or medical contraindication (e.g., difficulty breathing) may wear a face shield in lieu of a face mask; however physical distancing must be strictly enforced. Measures to reduce risk of exposure for these persons should be implemented, where possible.
• Staff and individuals who are unable to wear a face mask or face shield due to medical contraindications should wear approved and appropriate PPE based on job-specific duties and risks and maintain physical distancing as much as possible. Other individuals should also remain physically distant from those who are unable to wear a face mask or face shield.
• In accordance with the Reopen Illinois plan, when conducting CDS activities in a community based (31C) setting, staff and individuals should follow the masking guidance of the location they're visiting.

Facilities:

• If vaccination status can be determined for staff and individuals, providers may group fully vaccinated staff and individuals together and do not need to maintain 6 feet of physical distancing between staff and/or individuals.
• Signage should be posted, reminding individuals and staff to wash hands.
  • 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: https://dceocovid19resources.com/restore-illinois.
    • Use of arrows or directional symbols taped on the floor can indicate the direction of traffic.
• Non-professional capacity visitation should be discouraged. All allowed visitors must follow the same guidance as staff and individuals, including screening and the donning of a face covering.
• Avoid crowding on ingress and egress routes and, where possible, have separate entrances and exits.

Disinfecting/Cleaning Procedures:

• Please reference CDC guidelines for recommended practices on disinfecting.
• 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.

Programming and Support:

• For indoor facilities, capacity limits are now determined by the ability of the space to accommodate physical distancing for those vaccinated and unvaccinated/undetermined - not a set capacity limit, number or percentage of capacity.
• If vaccination status can be determined for staff and individuals, providers may group fully vaccinated staff and individuals together and do not need to maintain 6 feet of physical distancing between staff and/or individuals.
• Providers should consider making groups static based on proof of vaccination status, with no mixing of individuals and/or staff between groups.
• Multiple groups in one facility are permitted as long as consideration is taken for vaccinated and unvaccinated individuals.
• Within each room, individuals should be able to physically distance 6 feet if vaccination status has not been determined or the staff or individuals are unvaccinated. If physical distancing is not feasible, groups should be limited to people within the same household or activity should be suspended.
• Limit the number of people occupying restrooms at one time to prevent long lines or crowds.
• 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.
  • During lunch, physically distance staff and individuals of 6 feet if vaccination status has not been determined or the staff or individual are unvaccinated.
  • Sharing food or refreshments is prohibited for individuals and/or staff.
• Additionally, pay special attention to putting on and removing face masks for purposes of eating. The front of the face mask is considered contaminated and should not be touched during removal. Hand hygiene should be performed immediately after removal. See CDC guidance on how to safely wear and take off a mask for additional instructions.
• The following are still considered appropriate recommendations:
  • When possible and appropriate, programming should happen in the community or outdoors.
  • 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 transportation vehicles 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 prepare policies that support both vaccinated and unvaccinated/undetermined staff and individuals for safe transport.
• If vaccination status can be determined for staff and individuals, providers may transport fully vaccinated staff and individuals together and do not need to maintain 6 feet of physical distancing between individuals.
• 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 alcohol-based 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.
• Providers should ensure staff, driver(s), and individuals wear face coverings when in the vehicle.
• Procedures must support staff to maintain social distancing when loading and unloading.
• Unvaccinated or indeterminate vaccination status:
  • 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 they receive clearance from their medical provider to resume activities.

Billing:

• CDS programs may operate Monday through Friday for a minimum of 5 hours per day. CDS providers can bill for a maximum of 7 hours per day. Note: if multiple day programs or supported employment are 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, 31C, or 31V 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.
  • 31V billing will be used for CDS provided virtually.
• As previously stated in this IB, 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. Travel time from the final community location back to the individual's residence is not authorized to be billed.

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

Effective Date:

July 27, 2021