ODP announcement 21-016 states that:
Any individual who begins receiving services at a Community Participation Supports (CPS) facility on or after July 1, 2021 will be considered a new admission. CPS facilities must comply with the regulations exactly as written for all new admissions. We asked for the criteria to determine if services were provided in 20–21 since some individuals have not come face to face with staff; however, provider staff have maintained contact with them and their families or residential provider, participated in their Individual Service Plan (ISP) meetings, and completed their annual functional assessment and quarterly reviews throughout the year.  

ODP’s answer is as follows:
ODP acknowledges that viewing individuals whose CPS facility services were suspended due to COVID-19 such that the individuals were never discharged as “new admissions” can be challenging. However, many of these individuals have not received CPS services in a facility for over a year. It is highly possible that individuals will not recall their rights, fire safety procedures, and information about working hours, benefits, etc. Also, CPS facilities must recognize that individual’s needs may have changed over the past year, and a new assessment of those needs is essential to providing safe and effective services.

For this reason, all of the requirements relating to admission practices must be followed for individuals who begin receiving services on or after July 1, 2021 even if the person was never discharged from services. The exception is 55 Pa.Code § 2390.111 (relating to admission decisions).

Individuals do not have to be discharged and readmitted for the provider to be deemed compliant with regulatory requirements.

It is important to acknowledge that requirements relate directly to individual health, safety and rights; continued suspension of these regulations pose a significant threat to health and safety as well as create the potential for human rights violations. Please note that ODP analyzed the impacted regulations and has determined that compliance can be achieved with minimal administrative effort.