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AAW

ODP Announcement 22-103 serves to inform Adult Autism Waiver (AAW) providers that there are specific regulations regarding restrictive procedures that must be followed. The Office of Developmental Programs (ODP) has been made aware that some AAW providers are implementing restrictive procedure plans for individuals being served in AAW without a corresponding BSP documented in the ISP in HCSIS. This practice is not allowed.

A restrictive procedure must always be part of the behavioral support component of the ISP as required by the AAW. In the AAW, the BSP is included in the ISP in HCSIS. The Desired Behavioral Outcomes (DBOs) of the BSP must be consistent with the Behavior Support Specialist service goals and objectives.

There must be an active Behavior Support Specialist goal for each DBO, and each Behavior Support Specialist goal must have a DBO. Additionally, every Behavior Support Specialist goal must have a corresponding Goal Attainment Scale (GAS) chart and be reported on at least quarterly in a Quarterly Progress Note (QPN).

To have a restrictive procedure plan in place for an AAW participant, the Behavior Support Specialist service must be in the ISP Service Details so that a BS qualified to provide services in the AAW can develop, implement, and train staff on the participant’s BSP and CIP with the goal of fading all restrictive procedures over time.

In the AAW, the Behavioral Specialist Service (BSS) is not bundled with the Residential Habilitation service as it is with other ODP waivers. Therefore, to meet the requirements above, AAW participants who are receiving residential habilitation services and have a restrictive procedure plan in place must also have active BSS authorized in their ISP. This ensures an AAW qualified BS is working with the participant when a restrictive procedure plan is in place.

Please refer to Chapter 6100 regulations § 6100.341 – 6100.346, Bulletin 00-21-01 Guidance for Human Rights Teams and Human Rights Committees and Attachment 2 — Individual Plans and Informed Consent for additional information. Any questions should be sent to the AAW Provider Support Inbox.

ODP Announcement 22-085 announces clarification for Supports Coordination Organizations (SCO) on resuming Waiver and Targeted Support Management (TSM) Supports Coordination (SC) in-person monitoring. Many adjustments have been made to the Office of Developmental Programs (ODP) policy and operations during the COVID-19 pandemic. Appendix K allowed for SC services to be provided remotely during the pandemic. ODP planned to replace the Appendix K guidance with new requirements detailed in the Intellectual Disability and Autism (ID/A) Waiver renewals and the Adult Autism Waiver (AAW) amendment effective July 1, 2022, to allow for some SC individual monitoring to continue to be completed remotely.

Both the ID/A Waiver renewals and the AAW amendment are pending approval with the Centers for Medicare and Medicaid (CMS). Therefore, ODP is issuing guidance to clarify the expected requirements of individual monitorings performed by SCs. This announcement outlines the updated requirements for SC in-person and remote monitoring and obsoletes that section of Appendix K.

ODP expects SCOs that were unable to meet the June 30 deadline for completing the in-person monitoring for at-risk individuals to continue to follow their plan and communicate with the ODP regional office to ensure that all the priority individuals are seen in-person.

This announcement outlines requirements for SCOs to implement no later than October 1. For additional questions, please contact your appropriate ODP regional office.

ODP Announcement 22-059 informs readers that the Office of Developmental Programs (ODP) is pleased to announce that an amendment to the AAW was submitted to CMS on May 9, 2022. The submitted AAW includes modifications that were made as a result of public comment. The AAW amendment includes the following substantive changes:

  • Adding reserved waiver capacity for individuals who are discharged from a state center. Reserved waiver capacity is also being added for participants who have been incarcerated for more than six consecutive months;
  • Aligning provider qualifications in the AAW with the Consolidated, Community Living, and Person/Family Directed Support (P/FDS) waivers, whenever possible;
  • Allowing relatives to deliver the Life Sharing component of the Residential Habilitation service;
  • Requiring that agencies that provide Residential Habilitation/Life Sharing must be qualified and enrolled to provide Residential Habilitation/Life Sharing in the Consolidated or Community Living waivers;
  • Increasing the annual fiscal limit in the transportation service to $5,000 per participant’s ISP year;
  • Allowing one of the four required monitoring conducted by the Supports Coordinator each year to be conducted remotely;
  • Adding a new service, Remote Supports; and
  • Delivering direct services using remote technology.

The requirements in the AAW will become effective when Appendix K flexibilities expire, six months after the expiration of the federal COVID-19 public health emergency.

Please note that aligning the Assistive Technology service, where possible, with the Consolidated, Community Living, and P/FDS waivers includes adding generators for the participant’s primary residence.

The full AAW application, as well as a record of substantive changes, is available here.

CMS has 90 days to review the amendment, and changes may occur to the content based upon discussion with CMS during the approval process. The proposed effective date of July 1, 2022, is also subject to change. ODP will inform all stakeholders when CMS has officially approved the AAW and will make the approved waiver available at that time.

Questions about this communication should be directed via email.

The Office of Developmental Programs (ODP) has updated the AAW Provider Information Table and published ODP Announcement 22-038 to reflect the April 1, 2022, waiver amendment. Amended sections and new text in the table are highlighted in gray. The updated Provider Information Table includes these highlights:

  • Clarification that the waiver cannot be used to fund home accessibility durable medical equipment that is covered under the Medical Assistance State Plan.
  • Clarification of delivery of services while the participant is hospitalized. The requirements in the waiver will become effective when Appendix K flexibilities expire, six months after the expiration of the federal COVID-19 public health emergency.
  • Extension of timeframes for staff training or credentialing for employment-related service.
  • Increase in the threshold for obtaining an independent evaluation for assistive technology devices.
  • Clarification on the inclusion of physical restraints in the behavioral support plan.
  • Requirements for obtaining criminal history clearances for staff.
  • Aligning level of care reevaluation procedures with current practice.
  • Other changes designed to align the AAW, where practical, more closely with the Consolidated, Person/Family Directed Support and Community Living waivers.
  • Expanded sections on provider qualifications for each service.

Providers are reminded that they are responsible for being aware of any changes to definitions of services they provide and ensuring that individuals furnishing direct services are fully qualified before providing services to AAW participants.

The AAW amendment effective April 1, 2022, is available on the Department of Human Services’ website or here.

Questions or comments about this communication can be sent to ODP via email.

ARPA Funds and Credentialing Information
April 4, 2022, 1:00 pm–1:30 pm
Audience: Providers
Join Deputy Secretary Kristin Ahrens and Bureau Director of Policy & Quality Management Jeremy Yale to discuss the recent announcement about the ODP American Rescue Plan Act (ARPA) One-Time Supplemental Payment to Address Staff Training, Credentialing, and Business Associates Programs for Employment.
Format: ODP GoTo

Adult Autism Waiver (AAW) Updates
April 11, 2022, 10:00 am–11:30 am
Audience: All Office of Developmental Programs’ (ODP) AAW Providers and Support Coordinators
The purpose of the meeting is to provide updates on the Adult Autism Waiver, answer questions, and provide technical assistance and support. These meetings are held for all ODP providers and Support Coordinators providing AAW services. The Virtual Office Hours (VOH) starts with an overview of any new ODP Announcements and also includes a) highlights of new practices, b) a review of topics and questions sent in advance, and c) a discussion of any concerns that have come up in the past few weeks. Providers will be able to ask questions directly of AAW Regional Office (RO) Representatives.
Format: Columbus GoTo

Statewide Positive Practice Seminar
April 14, 2022, 9:00 am–3:00 pm
Audience: All Stakeholders
You are invited to participate in the Department of Human Services’ (DHS) Office of Mental Health and Substance Abuse Services (OMHSAS) and the Office of Developmental Programs (ODP) Statewide Positive Approaches & Practices Meeting.
TOPIC: Embracing Behavioral Supports and Meaningful Applications — Positive behavioral support is a process that combines evidence-based practices to address behavioral challenges and improve independence, participation, and overall quality of life of individuals living and learning in complex community environments. This session will engage participants to take an active role in behavioral interventions and expand one’s knowledge with principles and practices for dual diagnosed individuals and trauma.
Session #1 — Hard to Tell: What Individuals with Intellectual and Developmental Disabilities Need Us to Know about Trauma and Trauma-Informed Care
Dr. Caren Roser-Morris, Licensed Psychologist, OMHSAS.
Session #2 — The Importance of Quality of Life and Lifestyle Interventions in Behavioral Support
Jordan Hollander, Bureau of Supports for Autism and Special Populations Session
Session #3 — The Power of Collaboration Through Behavioral Assessment and Treatment
Lindy Mishler, Behavior Specialist, Bureau of Support for Autism and Special Populations Stacey Keilman, CEO, Torrance State Hospital.
Format: Columbus GoTo

Charting the Lifecourse Applying Principles and Using Tools to Support a Good Life for Individuals and Families
April 27, 2022, 9:00 am–1:00 pm
Audience: Individuals & Families
“Charting the LifeCourse” was created to help individuals and families of all abilities and all ages develop a vision for a good life, think about what they need to know and do, identify how to find or develop supports, and discover what it takes to live the lives they want to live.
Participants in this training will:

  • Learn About the National Charting the LifeCourse Community of Practice;
  • Apply LifeCourse Principles and LifeCourse Framework; and
  • Practice Using LifeCourse Tools.

Format: Columbus Zoom

Image by Dirk Wouters from Pixabay

ODP Announcement 22-030 shares that the proposed amendment to the Adult Autism Waiver (AAW) is available for public review and comment. There is a 30-day public comment period that starts on March 12, 2022, and ends on April 11, 2022.

The Office of Developmental Programs (ODP) is seeking your valuable feedback and comments. Information regarding the proposed waiver amendment changes, including how to provide comments, can be found in the Pennsylvania Bulletin, Volume 52, Number 11, which was published on Saturday, March 12, 2022. The waiver amendment and the record of change document are available here.

ODP Announcement 22-015 announces that the Operational Guide for the Adult Autism Waiver (AAW) has been updated to reflect current guidance from the Centers for Disease Control and Prevention (CDC), the Centers for Medicare and Medicaid Services (CMS), and the Pennsylvania Department of Health. Additionally, guidance has been added regarding regulatory compliance during the COVID-19 pandemic.

ODP Announcement 22-012 provides information regarding the Office of Developmental Programs (ODP) Bulletin 00-21-02, Incident Management, including the specific roles and responsibilities for Supports Coordination Organizations (SCOs). On June 25, 2021, ODP released Announcement 21-049 to clarify that SCOs were not expected to report more than what they were currently reporting until further notice. ODP is clarifying that announcement 21-049 does not apply to the Adult Autism Waiver (AAW).

SCOs serving individuals in the AAW have always been required to report all incidents that occurred in the absence of a provider rendering services at the time of the incident or if the target of an investigation is not an employee or volunteer of a provider organization. There has been no change in those requirements.

This data is critical to evaluating AAW program outcomes. Please note that with the release of ODP Bulletin 00-21-02 that was effective July 1, 2021, two new categories, Passive Neglect and Self-Neglect can be used to report incidents that were previously reported as Neglect when applicable. For further clarification on Passive Neglect and Self-Neglect, refer to the Learning Management System (LMS) for the recorded module on Enterprise Incident Management (EIM) System Changes, County Management and SC Incidents.

The SCO has a responsibility to respond to and assess emergency situations and incidents as well as assure that appropriate actions are taken to protect the health and welfare of participants. Incident management activities that are the responsibility of and completed by the SCO are billable activities. Billable incident management activities are considered part of the SCO’s function of location, coordinating, and monitoring.

SCOs are responsible for checking alerts generated by Enterprise Incident Management (EIM) that identify incidents entered for participants receiving services through their organization. SCOs shall monitor individual incidents in EIM and make recommendations to ODP regarding the appropriateness and effectiveness of the provider’s actions taken to protect the health and safety of the participant as described in the initial incident report. They must also monitor final EIM incident reports to determine if corrective actions are appropriate, revisions to the Individual Service Plans (ISP) are needed, or additional monitoring of the situation is necessary. Monitoring of incidents by the SCO is integral in helping the ODP incident management reviewer in making a determination regarding the approval or disapproval of the incident report.

For targeted technical assistance or questions, please contact ODP’s Bureau of Supports for Autism and Special Populations’ Provider Support mailbox.

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Adult Autism Waiver (AAW) and Adult Community Autism Program (ACAP) providers are invited to sign up for a scheduled one-on-one VOH session to discuss incident management topics with the Office of Developmental Programs’ (ODP) Bureau of Supports for Autism and Special Populations (BSASP).

Providers may sign up for one 30-minute session, and multiple staff from the provider may join at the provider’s discretion. Topics for discussion may include: provider-specific IM issues or concerns; EIM reports; general questions about certified investigations; brainstorming ideas of how to improve “performance” related IM tasks; review of provider IM data and compliance; discussion of provider trends; etc.

Due to the positive feedback received from attendees of our previous sessions, ODP will be offering additional 30-minute sessions on a first-come, first-served basis.

Sessions begin Wednesday, March 9, 2022, with the first scheduled session beginning at 12:30 pm.

Register here. Be sure to complete all required information to reserve a time slot.

Please contact the Provider Support Mailbox with questions.