Illinois Department of Human Services
Division of Developmental Disabilities
This Information Bulletin replaces policy/guidance previously given in DD.20.019.
This communication is intended to provide updated guidance on the remote provision of Individual Service and Support Advocacy (ISSA) monitoring activities.
Independent Service Coordination (ISC) Agencies are required to provide ISSA monitoring activities to individuals who are enrolled in a DD Medicaid Waiver program. Monitoring activities are provided to ensure the health, safety and welfare of each individual as well as to facilitate the Person-Centered Planning process. ISSA monitoring activities are categorized as 1) minimum required annual visits, 2) additional monitoring visits, and 3) other ISSA monitoring activities.
ISC agency staff conduct two minimum required visits each fiscal year: one visit to update the Discovery Tool and Personal Plan and another to assess the individual's satisfaction with the outcomes and services as well as to monitor their wellbeing.
The two Children's Waivers require a total of 4 visits a year: one visit to update the Discovery Tool and Personal Plan and the other three to assess the individual's satisfaction with the outcomes and services as well as to monitor their wellbeing.
The ISC shall perform additional monitoring activities as needed to ensure the health, welfare, safety, satisfaction and continued Waiver eligibility of the individuals. Prior to the Public Health Emergency and initial shelter in place order, the above-mentioned visits were required to be face to face.
The ISC agency can also perform other ISSA monitoring activities, as needed. This could include telephone calls, face to face discussions or electronic communications with families, guardians or provider agencies; this also includes reviews of records and other documentation.
In March 2020, the Division suspended all ISC in-home visits due to COVID-19 and the shelter in place order. Through the Emergency Preparedness and Response Appendix of the Waivers (Appendix K), the Division was able to allow ISCs to provide monitoring, as well as the creation and update of the Discovery and Personal Planning process, remotely. This Information Bulletin seeks to clarify the remote provision of these activities.
- In-person visits are allowed in both Phase 4 and the Bridge Phase.
- Conditions for limiting or suspending in-home visits
- ISCs should limit or suspend in-person visits when a region experiences the following:
- Substantial transmission (50-99 new cases per 100,000 population) or high transmission (=100 new cases per 100,000 population) in the last 7 days.
- Any regression in mitigation tiers
- County metrics can be found here.
Restarting ISC Visits:
- ISCs may resume face to face visits immediately, but no later than 7/1/21 based on the guidance below. This change is effective upon posting.
- It is expected that ISCs continue to monitor the health, safety and welfare of individuals as well as provide timely and updated Personal Plans during the pandemic.
- The number of ISSA monitoring activities should continue to be conducted based on the person's needs.
- Families and provider agencies are expected to follow guidance provided and are responsible for supporting the individual to participate in face to face visits or electronic, phone, and/or video communications if necessary. Visits should be arranged with sufficient advanced notice with families and/or provider agency staff to ensure proper support for the individual can be provided.
- The minimum required visits must be completed in the required time frames and documented as outlined in Section 9.2 of the ISC Manual.
- The ISC is required to follow up on any incidents reported through the Critical Incident Reporting Analysis System (CIRAS) as outlined in the CIRAS Manual. If an in-person visit is required, the ISC, provider, and family should follow guidance as provided below. This change is effective upon posting.
- Individual, guardian (if applicable), and family choices should be respected. Some individuals may choose not to meet in person. This may be due to the presence of household members with at-risk health conditions or for other reasons. The option of virtual services should continue to be available to families throughout all phases of the pandemic based on the choice and safety of the individual. This should be documented in the ISC's notes.
- In the event an ISC staff member does not feel comfortable with a visit due to the conditions in a home, they should discuss with their supervisor. If the supervisor agrees that a remote visit is warranted, then this should be documented in the ISC's notes.
- If a situation in a specific residential setting indicates a face to face visit cannot be safely accommodated at a specific point in time, the provider agency will work with the ISC and individual to find an alternate location, date/time, or method to conduct the visit.
Health and Safety Precautions by Vaccination Status:
- Health and safety precautions must be maintained during all in-person services whether staff are vaccinated or unvaccinated.
- Staff should wear face coverings over their nose and mouth during all in-person visits regardless of vaccination status.
- Staff and individuals at a residential setting or provider agency aren't required to provide proof of vaccination. If proof of vaccination isn't determined, individuals should proceed with guidance as if everyone isn't fully vaccinated.
- Fully vaccinated staff:
- Review the CDC guidance for the most updated guidance of the qualifications of "fully vaccinated" which may vary by vaccine.
- When any individual in the visited household is unvaccinated, precautions should be based on the level of risk of the unvaccinated individuals. See the recently updated CDC guidelines on people at increased risk for severe COVID-19 disease.
- Staff who are fully vaccinated should not conduct in-home visits if they have tested positive for COVID-19 in the last 10 days or if they are experiencing symptoms of COVID-19, regardless of the vaccination status of the family.
- ISCs should limit in-person visits for at-risk populations to staff who are fully vaccinated. This may require rearranging caseloads.
- Staff not fully vaccinated:
- The ISC should consider conducting at least once per week screening testing for COVID-19 among asymptomatic staff who conduct in-person home visits and are not yet fully vaccinated.
- The ISC should consider collaborating with their local health department or local health care providers (e.g., FQHCs, pharmacies, etc.) to conduct regular rapid antigen point-of-care (POC) testing for staff entering homes and schools.
Policies and Procedures:
Each ISC should develop policies and procedures for providing in-person services that include, at a minimum, the following areas. The policies and procedures should be available for review at the DDD's request. The DDD does not need to approve ISC policies.
- Pre-visit call
- Staff members with health conditions
- Personal Protective Equipment (PPE)
- Communication plans with families and agreement by all parties to in-person contacts
- Documentation for contact tracing
- Responding to COVID-19 symptoms
Specific Components of Policies and Procedures:
- Pre-visit call: ISCs should develop a pre-visit process to determine the safety precautions that need to be in place based on the health conditions of the individuals in the household. The purpose of this pre-visit call is to ensure it is safe for ISC staff to visit and the safety precautions everyone involved in the meeting need to follow.
- Staff members with health conditions: Your policies and procedures should define the provisions for staff with medical conditions that put them at increased risk for severe illness related to COVID-19. These policies and procedures must be consistent with current Illinois employer guidelines and CDC guidelines on fully vaccinated persons and at-risk medical conditions.
- Screening: ISCs should implement a screening protocol for staff to use prior to an in-person contact based on the most updated CDC screening guidance. ISCs should also familiarize themselves with CDC guidance for unvaccinated individuals who have travelled.
- Personal Protective Equipment (PPE): ISC agencies should require proper use of personal protective equipment (PPE), such as face masks. PPE should be changed and sanitized between contacts. Refer to Illinois guidance on face coverings for additional details.
- Communication Plans with Families/Provider Agencies and Agreement to In-Person Services: It is important that agencies develop plans to communicate with families/provider agencies about changes impacting their in-person visits.
- ISCs should develop communication plans for families/provider agencies prior to restoring in-person contacts or visits that describe what will be different about their experience than before the COVID-19 pandemic (such as use of PPE, materials, physical distancing, etc.).
- ISCs should seek feedback from families/provider agencies on their communications and approaches, once these new in-person contacts or visits are implemented.
- ISCs should develop communication plans for families/provider agencies and staff in the case of any COVID-19 exposures, while maintaining confidentiality of the exposed individual(s).
- Documentation for Contact Tracing: To the extent possible, ISC staff should also document any persons present during the time of the in-person contact or visit, even if those persons are not participating in the contact or visit. This documentation will support any contact tracing, should anyone involved experience COVID-19 symptoms or a confirmed case of COVID-19.
- COVID-19 symptoms: Any staff member with signs and symptoms of a respiratory illness or related illness should not report to work. If a staff member develops signs and symptoms of illness while on the job or if any person is found to be ill during an in-person contact or visit, the staff should stop working immediately, notify their supervisor and, follow state and local health department protocols, and self-isolate at home immediately. Refer to the CDC recommendations on "what to do if you are sick", "cleaning and disinfecting your building or facility when someone is sick", and "when you can be around others if you had or likely had COVID-19".
The following additional resources may be useful to programs when developing their policies and procedures: