Long-Term Services and Supports COVID-19 Response

• COVID-19 Disability Community Webinar Recording - May 29, 2020
• COVID-19 Updates Disability Community Presentation - May 29, 2020

• COVID-19 Disability Community Webinar Recording - May 15, 2020
• COVID-19 Updates Disability Community Presentation - May 15, 2020

• COVID-19 Disability Community Webinar Recording - May 8, 2020
• COVID-19 Updates Disability Community Presentation - May 8, 2020

• COVID-19 Disability Community Webinar Recording - May 1, 2020
• COVID-19 Updates Disability Community Presentation - May 1, 2020

• COVID-19 Disability Community Webinar Recording - April 24, 2020
• COVID-19 Updates Disability Community Presentation - April 24, 2020

• COVID-19 Disability Community Webinar Recording - April 17, 2020
• COVID-19 Updates Disability Community Presentation - April 17, 2020

• COVID-19 Disability Community Webinar Recording - April 10, 2020
• COVID-19 Updates Disability Community Presentation - April 10, 2020
• Crisis Standards of Care-Triage Standards - April 10, 2020

• COVID-19 Disability Community Webinar Recording - April 3, 2020
• COVID-19 Disability Community Presentation - April 3, 2020
• Payroll Protection Program Presentation - April 3, 2020

• COVID-19 Disability Community Webinar Recording - March 27, 2020
• COVID-19 Updates Disability Community Presentation - March 27, 2020​

• COVID-19 Disability Community Webinar Recording - March 20, 2020​
• COVID-19 Disability Community Presentation - March 20, 2020​

A:  Providers suspending or reducing services due to COVID-19 are required to notify members and their case managers by phone or email within 24 hours of the decision to suspend or reduce services. Providers should provide the CMA with a list of members impacted. Review Operational Memo OM 20-039 - Updated HCBS Provider Retainer Payments and Case Management Action Required for Closures Related to COVID-19.

A: SIS assessment interviews shall be conducted by alternative methods, such as video conference and telephone. If a case manager determines the member requires a Support Level Review based on an increased need due to COVID-19, the case manager may send in a Support Level Review request as normal.

A: Case managers should utilize electronic video (such as Apple FaceTime, Skype or Zoom) to complete routine monitoring unless the member only has the option to use a telephone. The case manager shall log a note in the Benefits Utilization System (BUS) indicating the communication method used to complete the monitoring. For non-routine contacts that may require face-to-face interaction, such as performing an investigation into a member’s health and welfare, the case management agency must follow COVID-19 Centers for Disease Control (CDC) guidelines for precautions and social distancing. Any monitoring that does not require face-to-face contact is required to be completed. For more detailed guidance, refer to Operational Memo OM 20-034 - Temporary operational changes for face-to-face member contact and assessment.

A: While components of a case management investigation may be able to be completed via telephone or other video conferencing, there may be activities that require an in-person presence as noted in the Operational Memo OM 20-034 - Temporary operational changes for face-to-face member contact and assessment. Any in-person activities should follow COVID-19 Centers for Disease Control (CDC) guidelines for precautions and social distancing.

A: HRC meetings can be conducted by alternative methods, such as video conference and telephone. All requirements for HRC, including informed consent, remain.

A: There have been no changes to the emergency enrollment request process. Community Centered Boards (CCBs) may continue to submit requests to the Department for those individuals who are seeking enrollment into the HCBS-DD waiver.

A: Department communication regarding PASAs and approved providers about CMA core work changes due to COVID-19 will continue to be made available through the Department Memo Series and captured on the Department COVID-19 website. Changes to case management or provider requirements are combined into joint memos to both audiences whenever applicable. All changes are communicated utilizing the Memo Series.

A: Case managers do not need to complete a service plan revision for a change in service delivery location. Please refer to Operational Memo 20-046 for more information pertaining to the temporary changes to waiver benefits.

A: Critical incidents involving COVID-19 must be identified through the documentation fields in the Benefits Utilization System (BUS). The Department released Operational Memo 20-044 to provide guidance regarding Critical Incident reports when a member reports they have a presumptive or confirmed case of COVID-19. 

For the Family Support Services Program (FSSP), State Supported Living Services (SLS) and Omnibus Reconciliation Act (OBRA) program, case managers will enter COVID-19 in the Critical Incident Reporting System (CIRs) in the existing DDDWeb/CCMS system and send a notification email to hcpf_cirs@state.co.us. Please note there is not a drop-down option in this system for COVID-19; therefore, the case manager must enter COVID-19 into the text field.

A. Case managers can accept an electronic signature on forms requiring a member or legal guardian signature. Please refer to Operational Memo 20-027 - Changes to Signature Requirements for Member Paperwork in Response to COVID-19 for Case Management Agencies.

A.  When processing a Continued Stay Review (CSR), the case manager does not need to wait for signed documents to proceed with the functional eligibility determination. The case manager can submit the level of care certification to the county and create the service plan and PAR. Services may begin prior to the receipt of signed required paperwork. Please refer to Operational Memo  20-049: Updated Case Management Additional Operational Changes in Response to COVID-19 for additional guidance on obtaining signatures and paperwork necessary to complete an enrollment. 

A.  An initial assessment or a Continued Stay Review (CSR)  for Home and Community Based Service waivers do not require a completed PMIP as outlined in Operational Memo 20-049: Eligibility and Notice of Action Changes in Response to COVID-19 for Case Management Agencies. The ULTC-100.2 and DSS1 should be finalized and sent to the county for processing.

A:  The Department issued guidelines for Providers and Case Management Agencies (CMAs) when there is a suspected or confirmed case of the COVID-19 illness in a residential setting. Those guidelines can be found in Operational Memo 20-035: Operational Information for HCBS Residential Services Pertaining to COVID-19. As always, the Department advises all members and providers to refer to the Colorado Department of Public Health and Environment (CDPHE) and the Centers for Disease Control (CDC) for best practices when dealing with a COVID-19 case.

A:  No it does not. If one or more members reside in the same household (Host Home, privately owned home, family home) and are exposed to one another or a regular basis, they may ride in the same vehicle together. The intention of this guideline is to prevent exposure and contact with other individuals, but if the members live in the same household, that precaution is unnecessary.

Operational Memo 20-031

A:  Yes, with Department approval. If a Day Program Setting can ensure that the two suites are operated as separate settings, which includes separate entrances, restrooms, staff, etc. and can keep the groups from interacting, then each setting can hold up to the maximum of 10 people (staff and members). The Department understands that many Day Programs have large settings and can accommodate more than 10 individuals while maintaining a 6-foot distance between members. However, due to the fact that the space, including entrances, restrooms and facilities are all shared, the 10-person maximum must remain in place for facilities like this. In order to obtain Department approval, please complete this form.

A:  No. Every member receiving Day Program services, as well as staff members, must wear a cloth face covering or mask. Colorado is still under the Safer at Home Executive Order, in which Day Programs are not deemed an "Essential Activity." If a member is unable or unwilling to wear a mask or cloth face covering in order to attend the Day Program, then they pose a risk to other members and should not receive services that are provided in a small group or at the setting. Day Program providers are expected to enforce this requirement if they choose to reopen or begin providing services in small groups or at the setting.

A:  Yes. Members who need assistance with daily living skills or mobility may return to their day program, if they are not considered "vulnerable," they are wearing a mask or cloth face covering for the duration of the day program, they are not showing symptoms of illness, and they are otherwise able to maintain social distancing from other participants while at day program. Please see Operational Memo 20-057 for details as to how Day Program can be provided under the Safer at Home order.

A:  Yes. The provider must work with the member and notify the case manager if services will be resumed, either in person or virtually. If a Day Program Provider is resuming services for that member, they would no longer be billing for retainer payments but for those services/units rendered.

A:  See Operational Memo 20-039: Updated HCBS Provider Retainer Payments and Case Management Action Required for Closures Related to COVID-19 for most recent guidance on retainer payments. 

For dates of service beginning March 13, 2020, providers delivering the following HCBS services may utilize service delivery alternatives or bill authorized retainer payments when services are no longer able to be rendered due to health concerns related to the COVID-19 pandemic (see below for process): 

• Adult Day Services 
• Day Habilitation 
• Day Treatment for the Brain Injury Waiver 
• Prevocational Services 
• Supported Employment  (including Supported Employment-Group)

NOTE: Any provider agency temporarily suspending or reducing services must immediately notify the Department, members, and the members’ case management agency (CMA). Provider agencies shall notify the Department by email at HCPF_HCBS_Questions@state.co.us.

Important notes about retainer payments:  

• Retainer payments may only be billed when authorized and documented by case managers via log note in the member’s file within the case management system, the Benefits Utilization System (BUS). 
• Retainer payments may not be billed when the member chooses to receive the service from a different service provider or alternative services in lieu of services identified above.  
• Retainer payments are received by billing for units authorized in a member’s service plan, but not provided due to the COVID-19 pandemic.  
• Units billed shall not exceed the amount, scope, and duration otherwise authorized for the Service provider.  

A:  See Operational Memo 20-039: Updated HCBS Provider Retainer Payments and Case Management Action Required for Closures Related to COVID-19 for most recent guidance on retainer payments. 

Important notes about retainer payments:  

• Retainer payments may only be billed when authorized and documented by case managers via log note in the member’s file within the case management system, the Benefits Utilization System (BUS). 
• Retainer payments may not be billed when the member chooses to receive the service from a different service provider or alternative services in lieu of services identified above.  
• Retainer payments are received by billing for units authorized in a member’s service plan, but not provided due to the COVID-19 pandemic.  
• Units billed shall not exceed the amount, scope, and duration otherwise authorized for the Service provider.  

What providers need to do to get retainer payments:

• Provider agencies shall notify the member and their case manager within 24 hours of the decision to suspend or reduce services by phone or email.   
• Providers must document the date/time of the phone call or email and who at the agency provided the notice.   
• All notifications must be documented, and all documentation must be maintained within the member file and provided to the Department or Department’s agent upon request.  
• Provider agencies shall notify the Department by email at HCPF_HCBS_Questions@state.co.us.   
• Provider agencies must wait to bill retainer payments until permission is given by the member and payments are authorized by the Case Management Agency.  
• Specific billing guidance is in OM 20-039 and below in this FAQ. 

A:  See Operational Memo 20-039: Updated HCBS Provider Retainer Payments and Case Management Action Required for Closures Related to COVID-19 for most recent guidance on retainer payments.

• Each CMA, when notified of an agency suspension or closure, must contact the impacted member as soon as possible to review alternative benefits and services to meet the member’s support needs.  
• When in contact with members, the CMA must work to identify any other potential changes that may be needed to the member’s services and supports.  
• Case Managers are to enter a log note in the Benefits Utilization System, documenting: 
  • Contact with the member or member designated contact; 
  • Services reviewed; 
  • Determination of service changes or natural supports to meet the member’s needs; and 
  • Member’s approval or disapproval of retainer payments for the provider.  
• If no changes in supports are identified after reaching out to the member, and the member approves of the provider billing retainer payments, the case manager will notify the provider that they may bill retainer payments.

A:  See Operational Memo 20-039: Updated HCBS Provider Retainer Payments and Case Management Action Required for Closures Related to COVID-19 for most recent guidance on retainer payments. 

All providers authorized to bill retainer payments will continue to bill for services that were prior authorized on the member’s service plan.  

For retainer payments in which claims have already been submitted and paid, please complete the following steps:  

• Identify claims that include lines for which retainer payments were billed. 
• Access the Provider Portal, select the claims on which a retainer payment was billed, and use the Adjust/Void/Copy button on the bottom to void the line for which services were rendered, only if rendered services and retainer payments we billed on the same claim.  
• You will then need to use Adjust/Void/Copy button on the bottom to adjust the retainer payment line. On the adjusted claim, add one unit of the service code T2034 without a modifier for the same dates of service as the retainer payment service. This will allow the Department to track claims for retainer payments.  
• Before submitting, be sure you have removed any lines on the adjusted claim for services that were not billed as retainer payments. 
• Submit a separate, new claim for the rendered service that was voided. 
• If the claim with the previously billed retainer payment has been suspended, the claim will need to be voided and rebilled, with the new code of T2034 included on the claim. Should lines on the suspended claim have been billed for services delivered conventionally or virtually, a separate claim will need to be submitted.   
• Providers can follow the detailed instructions provided in this Quick Guide on how to “Copy, Adjust, or Void a Claim.” If providers are unable to void the claims and need assistance, please contact the DXC call center at 1-844-235-2387 with the following information:  
  • Specify Provider ID, Client ID, and Dates of Service or ICNs.  

For all future claims for retainer payments, please complete the following steps:  

• Providers must separate claim lines billed for Retainer Payments from claim lines for services delivered remotely or via conventional methods. 
• Providers must add one unit of procedure code T2034 to claims that include lines being billed as retainer payments. This will indicate the claim is a retainer payment.  
• If any of the services listed above are included on a claim with procedure code T2034, they will be assumed to be Retainer Payments. 
• Bill services provided either remotely or rendered in a conventional manner, on their own separate claim. 

• Example: if six units are billed, and four are retainer and two are Zoom, the provider should bill all six units as a retainer payment, and include one line of T2034 on the claim. Further, the provider should document in the member's file that two hours were spent in direct contact with the member. You would then bill for the retainer payments per OM 20-039.  

A:  The Department is working to determine the appropriateness and priority of expanding retainer payments for additional services, as allowed by the Centers for Medicare & Medicaid Services (CMS). If there is any change to retainer payments, the Department will issue new guidance through the Memo Series and update on the Long-Term Services and Supports COVID-19 Response page. 

A:  Yes. Member’s may leave the house or have visitors, if appropriate.  Providers, members, and family should have a conversation and work together to make that determination. However, the Safer at Home order directs that all “Vulnerable Individuals” should continue to Stay at Home. Additionally, if a member resides in a home with an individual considered vulnerable, it is strongly recommended the member Stay at Home. This includes individuals who: 

• Are 65 years and older 
• With chronic lung disease or moderate to severe asthma 
• Have serious heart conditions 
• Are immunocompromised
• Are pregnant 
• Are determined to be high risk by a licensed healthcare provider are considered vulnerable under Executive Order D 2020 044  

If a member does leave the home, or has visitors, it is important to continue to practice vigilance and screening upon returning to the home.

A:  Yes. See Operational Memo 20-039: Updated HCBS Provider Retainer Payments and Case Management Action Required for Closures Related to COVID-19 for most recent guidance on retainer payments.

A:  Yes, individuals in Supported Employment-Group who are not working or had their hours reduced may apply for unemployment. For additional information on unemployment benefits please visit the Colorado Department of Labor and Employment website.  

A:  Yes, providers are encouraged to continue to utilize telephone or video conferencing methods to provide job coaching and job development services. Providers must use their best professional judgement to determine if a telephone or video conferencing visit would be beneficial and align with the member's employment needs and goals. Specifically, you can still use alternative service methods to provide and bill for Supported Employment (SE) Group if people are not working at their job site. Supported Employment services may be provided to assist with relevant training, job coaching and skill building ongoing.

Providers that determine telephone or video conferencing visits can meet the needs of the member must document the assessment and any concerns in the care plan. Providers then must inform case managers of care plan changes.

A: Throughout the COVID-19 pandemic, Health First Colorado (Colorado’s Medicaid program) is temporarily expanding its telemedicine policy to authorize the following:

• Expanding the definition of telemedicine services to include telephone only and live chat modalities.
• Authorizing Federally Qualified Health Centers (FQHCs), Rural Health Clinic (RHCs) and Indian Health Services to bill encounters for telemedicine visits.
• Adding specified Physical Therapy, Occupational Therapy, and Home Health, Hospice and Pediatric Behavioral Therapy services to the list of eligible telemedicine services.

Get additional guidance and visit our Telemedicine webpage for the most up-to-date guidance.

A:  Yes, therapeutic services may be conducted through virtual visits. To minimize physical contact between providers and members, the Department has issued an Operational Memo to provide alternative provision allowances. Please review Operational Memo 20-020 - COVID-19 Communication for HCBS Behavioral Therapy, HCBS-Bereavement Counseling, HCBS-Expressive Therapy, HCBS-Mental Health Counseling, HCBS-Movement Therapy, and HCBS-Therapeutic Life Limiting Illness Support Providers for further guidance for the following services: 

• HCBS Behavioral Therapy
• HCBS Bereavement Counseling
• HCBS Expressive Therapy
• HCBS Mental Health Counseling
• HCBS Movement Therapy
• HCBS Therapeutic Life-Limiting Illness Support

Providers conducting virtual visits must document services rendered in the virtual format within the care plan. Providers shall bill for services just as they currently do according to the Prior Authorization Request (PAR). Providers will not bill using telemedicine procedure codes, will not change the place of service on the claim to “Telemedicine”, nor do they need to modify their Medicaid enrollment. 

A: 

• Assistive Technology (available in the BI, CES, SLS waivers)
• Behavioral Management and Education (BI)
• Behavioral Therapies – Counseling, Assessment, and Consultation (DD, SLS)
• Behavioral Therapies – Line Staff (DD, SLS)
• Bereavement Counseling (CLLI)
• Wraparound and Intensive In-Home Support Services (CHRP)
• Expressive Therapy – Music Therapy and Art and Play Therapy (CLLI)
• Home Modification and Adaptations professional evaluations (BI, CES, CMHS, DD, EBD, SCI, SLS)
• Independent Living Skills Training (ILST – BI)
• Life Skills Training (CMHS, EBD, SCI, SLS)
• Mental Health Counseling (BI)
• Mentorship (SLS)
• Movement Therapy – Music Therapy and/or Dance Therapy (CES, CHRP, SLS)
• Peer Mentorship (SLS, DD, SCI, CMHS, BI, EBD)
• Substance Use Counseling (BI)
• Therapeutic Life-Limiting Support Illness Support (CLLI)

*Brain Injury Waiver (BI), Children’s Extensive Supports Waiver (CES), Children’s Habilitation Residential Program Waiver (CHRP), Children with Life-Limiting Illness Waiver (CLLI), Community Mental Health Supports Waiver (CMHS), Developmental Disabilities Waiver (DD), Elderly, Blind, and Disabled Waiver (EBD), Spinal Cord Injury Waiver (SCI), Supported Living Services Waiver (SLS)

Please refer to Operational Memo 20-046 for more information pertaining to the temporary changes to waiver benefits. 

A:  Providers who conduct virtual visits must clearly document services rendered in the virtual format within the care plan and notify the case manager of the change in service delivery. Providers should continue to bill for services just as they currently do according to the approved PAR. Providers will not bill using telemedicine procedure codes, will not change the place of service on the claim to “Telemedicine”, nor do they need to modify their Medicaid enrollment. 

A:  The new waiver in Section 1135(b) of the Social Security Act explicitly allows the Secretary to authorize the use of telephones that have audio and video capabilities for the furnishing of Medicare telehealth services during the COVID-19 pandemic. In addition, effective immediately, the Health and Human Services Office for Civil Rights (OCR) will exercise enforcement discretion and waive penalties for HIPAA violations against health care providers who serve patients in good faith through everyday communications technologies, such as Apple FaceTime or Skype, during the COVID-19 nationwide public health emergency. For more information please reference: OCR announces notification of enforcement discretion for TELEHEALTH REMOTE COMMUNICATIONS during the COVID-19 nationwide public health emergency.   

A:  The Department is covering some home and community-based services (HCBS) when provided over the phone, as a virtual delivery method. The integrity of the service must be maintained when providing services over the telephone.  Please review Operational Memo 20-020 and Operational Memo 20-046 for further information. Not all HCBS waiver services may be appropriately delivered via telephone. Providers must use their professional judgment when determining if a service is appropriate for virtual service delivery.

For any questions related to telemedicine and State Plan services, including Physical Therapy, Occupational Therapy and Speech Therapy,  please check the Department’s web page Telemedicine - Provider Information for updates.

A:  HCBS providers may only bill for the time and services rendered. The Department understands that many services are now being rendered via virtual or electronic means and these services may take less time to render than traditional face-to-face service delivery, or members do not have the technological means for virtual services, or members do not wish to receive virtual services for great lengths of time. However, regardless of the service delivery method, providers may only bill for services rendered, even if it is below the authorized amount in the Service Plan.