DHHS-OADS: Frequently Asked Questions and Resources Regarding COVID-19 for Agencies and Others Providing Supports to Individuals with Intellectual and Developmental Disabilities (IDD), Autism and Brain Injury

Frequently Asked Questions and Resources Regarding COVID-19 for Agencies and Others Providing Supports to Individuals with Intellectual and Developmental Disabilities (IDD), Autism and Brain Injury
​
Last Updated:  March 17, 2020

Prioritization for Treatment
 
1. Will people with disabilities be given lower priority for treatment at hospitals?   
No. Regulations require hospitals to conduct medical screening evaluations and admit, stabilize and discharge, or transfer based on the medical condition, need for treatment, and capacity to treat. A denial or restriction of treatment based on disability is a violation of the regulations.
 
Providing Education and Direct Supports to Individuals with IDD, Autism or Brain Injury
 
2. Is there a recommended screening protocol that agencies should implement for consumers/agency staff or family members prior to face to face visits?  
Yes.  Guidance from the Centers for Medicare and Medicaid Services (CMS) for home health agencies includes screening questions and actions:  https://www.cms.gov/files/document/qso-20-18-hha.pdf
The guidance addresses screening of staff, members/patients and visitors. You should implement a screening practice immediately if you have not already done so.
 
If this is a CMS certified ICF/IID facility they should be following the same guidance as LTC which can be found at: https://www.cms.gov/medicareprovider-enrollment-and-certificationsurveycertificationgeninfopolicy-and/guidance-infection-control-and-prevention-coronavirus-disease-2019-covid-19-nursing-homes-revised
 
3. Is there any specific guidance for Case Managers to replace face to face visits? 
Case managers/care coordinators can conduct assessments or other visits telephonically or by other remote technology to protect health and safety. We recommend that agencies follow their own protocols and telehealth/HIPPA compliant meeting policies which should be implemented at this time. 
 
4. What is the best practice when encouraging a consumer who may be non-compliant with self-quarantine or isolation? 
Education about COVID-19, which should be underway now, may help lessen the likelihood that a person receiving services will be non-compliant with good hygiene and home isolation precautions. Oregon has developed a video that can help explain COVID-19 to persons with IDD: https://youtu.be/MJ8eeC-tVD4
 
Maine’s self-advocacy group Speaking Up for Us (SUFU) is developing plain language materials and has offered to share those as they’re ready.  We will provide links as we receive them.
 
Consider and prepare now what may be needed in homes to help individuals with IDD be comfortable, should there be a need for them to remain in their homes for an extended period.
 
If a person is non-compliant with home isolation precautions or it is anticipated that this may be the case, the caregiver should consult with the person’s healthcare provider.
The caregiver should follow guidance from CDC about recommended precautions for caregivers in a nonhealthcare setting.  These can be found at: https://www.cdc.gov/coronavirus/2019-ncov/hcp/guidance-prevent-spread.html#precautions
 
5. Can you provide guidance on staff from different agencies/homes congregating for training? Is Zoom training recommended? 
On 3/15/2020, Governor Mills declared a state of emergency and asked that group gatherings of 50 or more attendees be postponed. Community agencies should consider reducing in-person gatherings to aid in social distancing. This is a good time to begin replacing in-person training with Zoom or other remote learning platforms.  Requirements for in-person training can be met using remote technology for as long as the COVID-19 emergency continues.    
 
6. Decisions made by one agency may impact another agency (e.g., a community supports provider suspending a particular group program which may impact the need for staffing at the residential agency).  How should providers coordinate decisions? 
Providers should notify other impacted agencies when they are considering decisions that may impact those other agencies.  Agencies should be creative as needed in developing short-term solutions, such as sharing staff, that will ensure the health and safety of people served.  OADS is exploring options for an electronic bulletin board or other tool for sharing information, but agencies should reach out to other agencies as needed to coordinate their actions.
 
7. Is it OK to reach out to families and guardians to assess what supports they may be able to provide if needed? 
Absolutely.  Some families and guardians may be willing, for example, to have their family member temporarily move to their home, but this is a conversation that should be happening now.  Please reach out to assess how each family member or guardian can help.
 
8. What is the guidance for people at higher risk and special populations?   
Guidance for people at higher risk and special populations can be found at: https://www.cdc.gov/coronavirus/2019-ncov/specific-groups/index.html.  At this time, people at higher risk are older persons and people of all ages with severe underlying health conditions — like heart disease, lung disease and diabetes.  Intellectual disability by itself has not been identified as a risk factor, but many people with intellectual disabilities do have severe underlying health conditions, placing them at greater risk.
 
9. Exactly what are the expectations for group homes in the event of a suspected or confirmed COVID-19 case of a resident or staff? Is the group home operator expected to manage the residents and staff?  
Group homes and other service providers are expected to manage situations as they arise, in accordance with CDC guidance.  This includes giving and enforcing clear guidance to their staff to stay home and call their doctors if they experience symptoms.  In urgent situations, agencies may need to employ temporary staff who have not completed the normal pre-service training.  In these situations, the agency should take whatever actions necessary to protect the health and safety of the people in its care.  The decisions—and costs if relevant- should be documented as they are undertaken. 
 
Agencies that have not already done so should review and update their plans for continuity of operations in the event of an emergency or disaster.  Agencies that have recently reviewed their plans report that they needed updating for a potential pandemic, as they were focused more on natural disasters such as hurricanes or floods.
 
If a person has symptoms of COVID-19, they should call their healthcare professional. https://www.cdc.gov/coronavirus/2019-ncov/about/steps-when-sick.html
 
For information about recommended precautions for caregivers in a nonhealthcare setting, please see: https://www.cdc.gov/coronavirus/2019-ncov/hcp/guidance-prevent-spread.html#precautions
 
Home care of people not requiring hospitalization https://www.cdc.gov/coronavirus/2019-ncov/hcp/guidance-home-care.html
 
Role of the Direct Support Professional (DSP) and the Coronavirus (3/11/20): http://bit.ly/3aPBQBh
 
10. Where can I turn if I think someone is at risk of abuse, neglect or exploitation during this period? 
You should do the same thing you would do during any other period:  submit a report to Adult Protective Services at 1-800-624-8404 or https://www.maine.gov/dhhs/oads/aps-guardianship/report.html.  Certified ICF/ID facilities also need to follow all other state and federal regulations that apply.
 
OADS Policy Questions/Considerations
 
11. Will the amount of time that a family/consumer has to accept an offer of Section 21 services be extended in a health emergency? 
OADS will not withdraw funded offers as long as we have information that there may be a health emergency and we are aware that the family/consumer is moving ahead with the process as soon as feasible.  If you require more time to exercise a Section 21 offer, please notify your case manager.   
 
12. Will there be any negative repercussions from OADS if the agency and guardian(s) decide to keep a person home from day programs that have large congregate settings? 
The agency staff should speak to the person and the case manager about possibly choosing individualized community options if available.  OADs expects agencies to make decisions based on their own polices and to keep the health and safety of the individuals they are serving first and foremost when making these decisions. 
 
13. If Agencies are implementing the CDC guidance re: older adults & those with health conditions should stay in their homes, avoid large crowds, etc. do we need approval from OADS as this violates the Community Rule?  
OADs expects agencies to follow CDC guidance and make the best decisions they can based on the health and safety of the individuals they are serving.  As long as participating in community events does not violate federal, state or local public health guidance, the provider should help the individual make an informed decision regarding their level of participation in the community, but DHHS recognizes that staffing constraints and other operational needs may make it impossible for agencies to fully support individualized choices.  
 
14. Will there be any unique communication protocols if an agency needs to close a home?   
If individuals need to be moved to a different home, the provider should document the need, including that the consumer and/or guardian has been notified and call OADS’ Clinical Review Team to submit the request.
 
15. How will OADS communicate with IDD stakeholders going forward?    
This document will be updated as guidance changes and more questions are answered.  OADS will also have weekly open stakeholder calls to provide updates and hear directly from all stakeholders.  (As with the CDC calls, these are not intended for the press.) The CDC should still be considered the best resource for current information about COVID-19 in Maine, and for current guidance on best practices.  OADS will post this document and other IDD-related guidance on its website.
 
If you have questions that you would like addressed on these calls, or questions in general during this time, please use the [email protected] e-mail address and put “COVID-19” in the subject line.  This mail box is checked throughout the day and questions are forwarded to the appropriate staff person for a response.  In between calls, as updates occur that we feel should be shared sooner, we will send e-mails through our list-serve.