Authors Posts by Carol Ferenz

Carol Ferenz


Dear RCPA members,

Here is a link to a survey we are conducting to assess the impact of COVID-19 on CPS providers. This information will allow us to advocate for your financial needs in the most effective manner. As you are aware, the retainer payments for providers who operate in counties designated as “green” in PA, will receive a retainer payment of 25% beginning in July, and at this time it is anticipated that the retainers will only continue through September.


In order to prepare you for the survey, the questions are included here so that when you open the link, you will have the information you need to complete the survey. We appreciate your participation and realize that this could take some time for you to complete. As a result, we have included a few detailed questions at the end that are optional. If you are able to provide that information, we would be grateful. If you are not able to complete the last section, submitting answers for the other questions will still be very helpful to us in our advocacy efforts.

Thank you and if you have any questions, please feel free to contact Carol Ferenz.


ACL From Our Partners
Webinar 7/23: Sick and Tired of Being Sick and Tired: People of Color, Disabilities, and Mental Health

Register for the webinar on Thursday, July 23, at 2:00 PM ET.

The Mental Health and Developmental Disabilities National Training Center (MHDD-NTC) presents a webinar exploring the unique intersection of disability, mental health, and people of color. People of color experience higher rates of disability and mental health conditions, but often face decreased access to care and have other co-occurring health disparities. This presentation will highlight these inequities and discuss how we can work towards eliminating these disparities and becoming stronger allies for people of color.


Morénike Giwa Onaiwu is an educator, writer, public speaker, parent, and global advocate. A proactive, resourceful professional and disabled woman of color in a multicultural, neurodiverse, serodifferent family, Morénike, who is American-born to immigrant parents, possesses undergraduate and graduate degrees in International Relations and Education. She has been the recipient of numerous awards, including the “Advocating for Another: Health Activist of the Year” 2014 WEGO Health Award and the “Service to the Self-Advocacy Movement” 2015 Autistic Self Advocacy Network Award.

Register for the webinar.

ACL funds the Mental Health and Developmental Disabilities National Training Center (MHDD-NTC). Learn more at

ODP has issued an updated Announcement 20-066 to provide guidance on establishing visitation policies in residential settings when a county transitions to the Green Phase of Governor Wolf’s Process to Reopen Pennsylvania. Residential settings include licensed and unlicensed community homes (55 Pa. Code Chapter 6400) and licensed and unlicensed family living homes (55 Pa. Code Chapter 6500).

The updated information addresses how to handle when individuals may wish to participate in a home visit with their family. Providers should establish a written policy for visits to a family home. This policy should include at a minimum:

  • Prior to the individual leaving the residence, the provider will conduct a screening of those people with whom the individual will have contact during the home visit. The policy should indicate the COVID-19 screening questions that will be asked. Providers should update the screening questions as necessary to reflect best practice for screening questions for COVID-19.
  • The provider will ensure that the individual and family are aware of Governor Wolf’s Green Phase social restrictions and encourage the individual and family to comply with them.
  • Prior to the individual’s return to the residential setting, the provider will complete a COVID-19 screening for the individual, remotely, within 24 hours of the planned return.
  • Upon the individual’s return to the residence, the provider will complete a COVID-19 screening.
  • If the individual is symptomatic or has had a known exposure to COVID-19 during the family visit, the provider will immediately quarantine the individual until such time as a negative COVID-19 test result is received from a test given to the individual after their return to the residential setting; or the individual remains without symptoms and meets the PAHAN 504–UPD criteria to be released from quarantine.
  • If the individual is symptomatic, the provider will test the individual for COVID-19 as soon as possible.

Providers should discourage home visits to counties that are not in the Green Phase.

CMS has posted additional Medicaid & CHIP COVID-19 FAQs on June 30, 2020, designed to aid State Medicaid and CHIP agencies in their response to the pandemic. The FAQs address key questions on Home and Community-Based Services; the Money Follows the Person program; and Advance and Retainer Payments (for home and community-based services). Topics include:

  • Eligibility and Enrollment;
  • Notice and Fair Hearings;
  • Optional COVID-Testing Group FAQs;
  • Premiums and Cost Sharing;
  • Benefits;
  • Non-Emergency Medical Transportation (NEMT);
  • Information Technology; and
  • Financing

In the Financing Q&A section (beginning on page 23 of the document), there are several items that providers should pay close attention to.  On pages 24 and 25 the guidance regarding Retainer payments presents guiderails that states are expected to follow.  An excerpt is below:

States interested in utilizing retainer payments for multiple (up to three) episodes of up to 30 days per beneficiary will be expected to include or add the following guardrails in their Appendix K submissions:


  • Limit retainer payments to a reasonable amount and ensure their recoupment if other resources, once available, are used for the same purpose. In terms of setting a reasonable amount, a retainer payment cannot exceed the payment for the relevant service; the state may specify that a retainer payment will be made at a percentage of the current rate, or a state may specify retainer payments will not be made to a setting until attendance is below an identified percentage of the enrollment (e.g., 75 percent).
  • Collect an attestation from the provider acknowledging that retainer payments will be subject to recoupment if inappropriate billing or duplicate payments for services occurred (or in periods of disaster, duplicate uses of available funding streams), as identified in a state or federal audit or any other authorized third party review. Note that “duplicate uses of available funding streams” means using more than one funding stream for the same purpose.
  • Require an attestation from the provider that it will not lay off staff and will maintain wages at existing levels.
  • Require an attestation from the provider that they had not received funding from any other sources, including but not limited to unemployment benefits and Small Business Administration loans, that would exceed their revenue for the last full quarter prior to the PHE (public health emergency), or that the retainer payments at the level provided by the state would not result in their revenue exceeding that of the quarter prior to the PHE.
  1. If a provider had not already received revenues in excess of the pre-PHE level but receipt of the retainer payment in addition to those prior sources of funding results in the provider exceeding the pre-PHE level, any retainer payment amounts in excess would be recouped.
  2. If a provider had already received revenues in excess of the pre-PHE level, retainer payments are not available.

CMS also clarifies that consecutive days are those days that are eligible for billing. As typical day habilitation services are rendered Monday through Friday, 30 consecutive billing days would encompass a 6-week period of time.

These newly released FAQs have also been integrated into the previously released COVID-19 FAQ document, available online.

Late last week, Politico Pro published and HHS later confirmed that providers who were left out of the latest Medicaid tranche from the provider relief fund will be getting another chance. While no official timeline has been finalized, Hill staff confirm that HHS is close to announcing more specifics.

The HHS spokesperson said any provider that missed the deadline will be able to apply. They will be eligible to receive 2 percent of their revenue from seeing patients. More guidance will be forthcoming, the spokesperson said.

See the Politico Pro article for more on what we know at this time.

Senator Casey will be hosting a virtual Disability Employment Summit on Friday, July 24, 2020. The summit is scheduled from 10:30 am to 11:45 am. We will examine the impact of the novel coronavirus (COVID-19) health crisis on disability employment, as well as discuss strategies to improve the disability employment rate and ensure people with disabilities are able to return to work. An agenda and registration information will be sent closer to July 24.

Senator Casey hopes that you mark the date on your calendar! If you have any questions, please reach out to Josh Dubensky or Josh Kramer.

August 5 – August 7, 2020

Online Zoom Meeting from 9 am – 4 pm

This 3-day training provides a comprehensive overview of Discovery (an alternative to traditional vocational assessments) and how to complete Discovery. For those seeking to become certified providers of Discovery through Marc Gold and Associates, it is the pre-requisite training for certification. Individuals not seeking certification will gain valuable information and insight and may attend as auditors of the course.


  • Job Coaches and Job Developers
  • Supports Coordinators
  • Parents and Families
  • OVR Counselors
  • Transition Coordinators
  • School Transition Teams


For questions and more information please contact Jennifer Hipps.