Over the past 48 hours, there have been several updates pertaining to the COVID-19 public health emergency. The Arc New York continues to monitor the Centers for Disease Control and Prevention (CDC) and New York State Department of Health (NYSDOH) activities to stay up-to date with the latest information and guidance. We are also working closely with the Office for People With Developmental Disabilities (OPWDD), the Care Coordination Organizations (CCOs) and Arc New York Chapter leadership to develop strategies and meet state and federal goals for limiting the spread of COVID-19
As a reminder, we maintain The Arc New York resource materials and links to reliable sources of information on The Arc New York website.
We have begun to receive reports of Chapters being directed to implement precautionary and mandatory quarantines of individuals and staff. There have been a number of instances where the guidance of local health officials has been contrary to published DOH/OPWDD COVID-19 protocols. As we are all learning the process that the Local Health Departments (LHDs) follow, we ask that you share with us your experiences, and reach out to us immediately should local guidance be incompatible with the specified written guidance. There may be times where we need to support the Chapter through navigating the quarantine process or in advocacy with OPWDD Central Office leadership. As you experience cases, please reach out for support, guidance and information sharing by contacting Josh Christiana, Erik Geizer and John Kemmer.
Community Engagement in Times of Increased Restrictions
As the federal, state and local officials direct additional measures to control the spread of COVID-19, the lives of the individuals we support are fundamentally impacted. Routine daily community activities are limited as part of the larger mitigation strategy. While these strategies are important to reduce transmission within our communities, it remains crucial that we continue to find ways for individuals with intellectual and developmental disabilities to remain involved in their community.
As we respond to this health crisis, we must balance the rights of individuals with appropriate measures to reduce transmission. OPWDD's guidance on screening and limiting visitors should be the foundation of our strategy prior to implementing a blanket policy of restriction on visitation. At this time, OPWDD is not permitting blanket restriction on visitors to IRAs, as such restrictions would be in violation of Rights and Responsibilities of Persons Receiving Services (NYCRR Title 14, Section 633.4(xxiv)) and HCBS Settings Requirements (NYCRR Title 14 Section 636-2.4(a)(8)). However, Chapters are welcome to request that families refrain from or limit their visitation at this time. A template letter to families requesting limited visitation can be found here.
We must look to the guidance of local health departments on what level of social engagement is safe and what limits are appropriate to set. This remains true for meaningful activities in the home and community. Chapters should continue to find ways expose individuals to their surrounding communities by bringing information and community activities into the home, while also allowing for travel into the community following the health department standards for prevention. Blanket policies of suspension of community outings and activities should not be the core of a strategy to mitigate exposure at this time.
Notification of Closure Materials
On Tuesday morning, OPWDD issued a directive that all Day Habilitation, Day Treatment, and Prevocational services would be temporarily suspended. The Arc New York Chapters are required to submit a plan for temporary suspension to OPWDD. They provided a template Excel workbook to be used for plan development. OPWDD has advised that providers must submit a plan per program site. Additionally, if a provider submitted a plan in a format different than the template they must resubmit.
We have identified some issues with the template document and OPWDD is working on corrections. Chapters should continue to develop and submit their plans to OPWDD at email@example.com. We ask that Chapters provide their plans to The Arc New York so that we may continue to share samples as needed. Completed plans can be sent to Josh Christiana.
Group Day Habilitation Inside the IRAs & Life Plan Addendums
With the suspension of day services, there is a great deal of uncertainty about programming for impacted individuals. Chapters are permitted to deliver day habilitation services within the certified Individualized Residential Alternative (IRA). Services should be delivered in accordance with the goals/supports/task as identified within the individual's Staff Action Plan (SAP). Staff delivering the service must have their time correctly allocated to the day habilitation service.
At this time, Chapters should proceed with plans for alternative programming within the IRA in leu of an addendum to the Life Plan. Chapters should communicate the intention to deliver Group Day Habilitation within the IRA via written correspondence to the individual's Care Manager. The correspondence should be kept in the individual's file.
We have been told that providers are not required to complete addendums at this time, but we have not received any concrete direction in writing. We are looking to get clarity of this matter quickly. If a CCO requests an addendum at this time, w
e recommend that Chapters consider using this
when notifying the Care Manager.
OPWDD's directive to suspend select services allows the option of providing alternative programming to individuals who do not have the necessary supports to remain at home during the day (e.g., individuals with elderly caregivers who rely on the supports of day programming). Chapters should reach out to all caregivers to determine their capacity to care for their loved one during weekday hours. Alternative programming may include the use of a program location where caregivers drop off their loved one, transportation, or even temporary respite to families in their homes may be provided. Chapters may keep a site available to support these individuals. However, they must also consider health official guidance regarding size of gatherings and the ability to implement the recommended social distancing. Administrative offices may also remain open for staff to continue to complete their job duties.
Template Program Suspension Letter
Notifying individuals, families, and staff of a significant change, such as the suspension of program services, is critical to reduce uncertainty and provide a point of contact for questions. We received several inquiries about the availability of template letters. We developed template letters for families and for staff as an optional resource to aid Chapters in this important notification. These letters have already been provided to Chapters, but are included again for ease of reference.
Template Confirmed COVID-19 Notice Letter
As the spread of COVID-19 increases, we have received notice of some confirmed cases. It is critical to keep all stakeholders apprised of the Chapter's status and ongoing efforts to address any confirmed cases. A template letter for Chapters to distribute to families and staff can be found here.
Direct Support Professionals Defined as Essential Employees
Guidance issued by the New York State Education Department (SED) classifies DSPs as essential health Care Workers. The SED guidance can be found
, and a related OPWDD memo can be found
. As S
ED explores options for providing childcare to those designated "essential health care workers,"
The Arc New York advocated with
New York Disability Advocates (NYDA)
for the inclusion of DSPs in this important classification. Broader implications of the designation will be discussed on today's call with OPWDD and more information will be provided as it becomes available.
IMU COVID-19 Contact Tracking Form for Individual
When a Chapter makes notification to the New York State Justice Center or OPWDD of the local health departments determination of isolation or quarantine of a staff or individual, OPWDD's Office of Internal Investigative Affairs will reach back out to gather additional information. This information gathering is used to assist OPWDD and the NYSDOH with contact tracking of COVID-19 cases. OIIA provided a "Contact Tracking Form" to be completed and submitted. OIIA will follow up with the Chapter within 24 hours.
We have raised concerns to OPWDD regarding the length of the form and volume of information that is being requested during this time where Chapters are focused on COVID-19 mitigation strategies. We have requested a review of the document to identify the most critical information OPWDD must have to achieve its goals. OPWDD has agreed to meet with a small group of Provider Association representatives that includes The Arc New York.
We are sharing this document so that Chapters may prepare staff for what information and records will be requested in response to completing the quarantine or isolation notification requirements.
We will provide additional updates on our advocacy efforts in this area as they become available.
As a reminder, OPWDD is offering two training webinars titled, "Containment Measures for COVID-19." The webinars are scheduled on Thursday at 11 a.m. and Friday at 4 p.m. Each will cover the same material. Registration information can be found in the link above.
Please make sure that Residential, Day Program and Nursing management view this webinar. It is being recorded and will be posted to OPWDD's SLMS website.
Please contact us if you have questions regarding any of this information.