The California Department of Social Services (CDSS) has issued an All-County Letter (ACL) to implement Telehealth Reassessment Options for In-Home Supportive Services (IHSS).
Due to COVID-19, California declared a state of emergency which authorized the IHSS program to conduct assessments and reassessments over phone or video call. This authorization ended when the state of emergency ended on February 23, 2023
On May 1st, 2024 the federal government approved State Plan Amendments that authorize the Telehealth Assessment Option for the IHSS programs.
Telehealth Reassessment Options will allow reassessments by phone or video call for any IHSS recipients who choose to participate and are determined eligible by county staff. To be eligible recipients must have stable care needs, have received an initial in-person assessment, and one in-person reassessment. In-person reassessments are the default and participants must opt-in to telehealth reassessments. Recipients cannot have consecutive telehealth reassessments unless there is a State of Emergency. Recipients will be reevaluated for eligibility before every telehealth reassessment.
All counties must implement the Telehealth Reassessment Option sixty days after completing computer system changes. Counties can choose to begin implementing this option after the publication of this letter, However, counties must manually research cases to determine eligibility and can use scheduling and assessment practices used during the COVID-19 pandemic. Recipients who have not had an in-person reassessment due to COVID-19 must receive one before using the Telehealth option.
Recipients must be able to independently use the technology required for telehealth or have someone assist them. This ensures that they can fully participate in the reassessment. In-person assessments must be conducted every other year and telehealth cannot be used for quality assurance or program integrity home visits.
To qualify as having “stable care needs” the recipient must meet 10 criteria at the time of reassessment. First, telehealth recipients must be 19 years of age with minors being ineligible due to changes in need of care. A minor who turns 18 must have one in-person reassessment after their birthday to qualify. Second, recipients cannot have had any incidents involving Adult Protective Services or other similar agencies. Third, there can be no documented concerns about health or safety and no suspicion of fraud in their case. Fourth, recipients cannot have been hospitalized or admitted to an overnight facility for 24 hours nor had multiple ER or urgent care visits in the last 3 months. Fifth, the recipient must not have had a gap in provider services in the last six months ensuring that needs are being met. Counties can use the 60-day no-activity report to identify cases that have gaps in provider services. Sixth, they must not have changed residence since the last reassessment. Seventh, they live with others when in need of assistance with memory, orientation, and judgment (MOJ), or they live alone and do not need assistance. If they have rank 2 or 5 in MOJ and live with others, they must have access to additional resources and support and are determined to have stable care needs. A recipient who lives alone should be rank 1 and not require any assistance with MOJ or need additional assistance. Eighth, the recipient cannot have an authorized representative who directs all care needs. Ninth, the recipient must not require assessment or reassessment for protective supervision. Finally, 10th, the recipient must not have complex paramedical needs. If a recipient has management through another program that helps stabilize them but does not meet all the criteria above, they can receive an exception as it pertains to stable care.
During a State of Emergency, recipients of impacted countries can receive telehealth reassessments regardless of stable needs criteria. When conducting a reassessment, the county is expected to fulfill documentation requirements for completion of an annual reassessment. The recipient must be in their home environment for the reassessment regardless of whether they are participating in the telehealth option. If a country cannot visually assess the recipient and their environment during the telehealth reassessment, they must ask questions to obtain the same information they would have during an in-person reassessment and document it. All standard forms are still required and original signatures are needed on forms that require it. When doing assessments with recipients with language or communication barriers the county must ensure the recipient’s comfort and provide translation services. (ACL 24-72, October 8, 2024.)