Interim housing and homeless program guidance on COVID-19

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The California Department of Social Services (CDSS) has issued guidance regarding CDSS housing and homeless programs for COVID-19.  The guidance relates to CalWORKs Homeless Assistance (HA), CalWORKs Housing Support Program (HSP), Bringing Families Home (BFH), Housing and Disability Advocacy Program (HDAP) and Home Safe.

CDSS does not limit the number of days of interim shelter, including nights in a hotel or motel, for HSP, Bringing Families Home, HDAP and Home Safe.

HA applications are not required to be in person or to include a face-to-interview.  Counties can complete the CW 42 application form for the client and have then sign electronically.  Existing rules requiring issuing 3-days of benefits while homelessness is verified remain in effect.  However, counties are strongly encouraged to issue benefits without requiring clients to come to the office, including allowing sworn statements and granting good cause instead of requiring clients to come to county offices.  Although existing guidance requires counties to issue vendor payments when there has been a finding of mismanagement, if there is no feasible way to issue vendor payments because of COVID-19, counties should consider issuing benefits on the client’s EBT card.

Clients affected by COVID-19 may be eligible for an exception to the once-every 12 months rule for HA.  For example, if a parent in an assistance unit is concerned about infection and asks to isolate themselves, HA should be granted based on an exception because of illness.

HDAP funds can expand existing housing options used by HDAP clients, including shelters, recuperative care housing, hotel or motel leases, or interim housing programs.  For example, expanding a shelter program could include offering specialized quarantine options or leases with motels to provide housing for homeless persons impacted by COVID-19.  Counties can also purchase supplies for a specialized quarantine area or establish a new shelter program for HDAP clients specific to COVID-19.  In addition, HDAP funds can be spent on outreach to locate persons potentially eligible for HDAP who are residing in homeless camps who require medical care related to COVID-19.

Home Safe funds can be spent on landlord engagement, including incentives for landlords to participate in Home Safe.  Such payments can include in-kind goods to address COVID-19 impacts such as medical or sanitizing equipment and supplies.  Home Safe funds may also be used for interim housing, including motels.

HSP funds can be used for a range of financial and supportive services, including providing interim housing, helping participants navigate systems of care, providing rental assistance, incentive payments in the form of good for landlords participating in HSP, and supplies necessary to keep housing habitable.  Counties can provide landlord mediation and discussion of tenant’s rights to avoid eviction or housing displacement.

BFH for families experiencing homelessness or at risk of homelessness with an open child welfare case can include interim housing, tenant engagement, case management, public systems assistance, and conflict mediation with landlords or neighbors.  BFH can locate and pay for motel stays for families seeking interim housing that is not a shelter.  BFH can also pay for cleaning supplies.

A three-day notice to pay rent or quit meets eligibility requirements for HA, BFH, HDAP and Home Safe.  HA can be used to pay up to two month rental arrearages to prevent eviction.  (ACWDL, March 19, 2020.)

The HA provisions of this letter are superceeded by All County Welfare Directors Letter, March 31, 2020, summarized here.

Child Welfare and Probation services during COVID-19

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The California Department of Social Services (CDSS) has issued guidance to child welfare agencies and juvenile probation departments on operation and providing services information regarding changes child welfare services and probation because of COVID-19.  Except for disaster planning, this ACL superceeds ACL 20-23 issued on March 13, 2020.  Counties must ensure continuity of services.  Even if counties operate with reduced face-to-face contact, counties must continue to address safety needs to children reported to be abused, children in foster care and children who remain at home who receive child welfare services.

In the event of an emergency placement, families are generally required to submit fingerprints for background check within 10 days or 5 business days of receiving the emergency placement, whichever is sooner.  If live scan is not available, the county can rely on results from California Law Enforcement Telecommunications System (CLETS).  Live scan should occur within 15 days of when services are restored and stay at home order is lifted.

Children and families receiving Family Maintenance services can have monthly caseworker visits by videoconference because of emergency.

For children in foster care, the federal government will now allow monthly caseworker visits by videoconference when an emergency prevents face-to-face contact.  Whether a monthly visit should occur in person is a child-specific decision to be made by the social worker. Videoconference is recommended as the first alternative.  Counties should assess if weekly or bi-weekly video contact should occur.  Telephone calls acceptable if videoconferencing is not available.

For nonminor dependents, monthly visitation can occur through viderconference, telephone, or courtesy supervision by a tribal representative or another Title IV-E agency.  Regardless of how monthly visits are done, case workers must ensure that nonminor dependents have resources and a plan for following local public health guidance, including housing, food, water, hygiene and other needed items.

Counties must contact non-minor dependents who are in school to ensure that they have necessary resources while they are out of school and to assist in returning to campuses when schools reopen.  If a youth is displaced from their dorm, counties should continue Supervised Independent Living Program payments until they find a new or temporary residence.  To assist with online classes, iFoster is offering free unlimited hotspots, headsets and laptops to assist with taking online classes.

Foster parents should provide videoconferencing with other family members if face-to-face visits do not occur.  Counties should assess each situation individually to make this determination.  Face-to-face visits should continue for children under age 3.

Social workers should maintain telephone contact and engage with parents and guardians.  Caseworkers should empower parents to use community support systems and to continue talking prescribed medications.  Caseworkers should assure parents that services discontinued or interrupted will not impact the assessment of whether they are in compliance with court-ordered reunification services.

For youth placed out of state, monthly visits must continue.  The social worker or probation officer determines whether the monthly visit will occur in person.  If a face-to-face visit is not necessary to ensure the child’s safety and well-being, videoconferencing is the first option for communication.  Counties should contact CDSS for assistance if there are problems related to travel restrictions for face-to-face visits.  CDSS will work with other states to facilitate visits.  Counties should be flexible with other states that request assistance with face-to-face visits.

Child and Family Team meetings are an important strategy to ensure families and providers can continue caring for children and counties are aware of the needs of children and caregivers.  Meeetings can be conducted by videoconference.

Post-placement supervision visits with children and youth in adoptive placement can be conducted by alternative means including videoconference based on the individual circumstances of the case.

If a child welfare agency is contacted by a parent who wishes to relinquish their non-dependent child for adoption, counties should consider entering into a voluntary placement agreement and postponing accepting relinquishment until face-to-face visits resume.  Agencies should not accept relinquishments by videoconference or telephone.  When agencies accept relinquishments, the requirement of two witnesses to the birth parent signing the relinquishment in person and the requirement that the birth parent receive appropriate counseling and advisement prior to signing remain in place.  (ACL 20-25, March 21, 2020.)

Temporary Waiver of Servicing Policy Regarding In-Person Borrower Contact

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The United States Department of Housing and Urban Development (HUD) has issued a waiver of its requirement that mortgagees have face-to-face contact with borrowers to determine the borrower’s circumstances and appropriate repayment plan because of COVID-19.  This waiver is limited to Single Family Mortgage Insurance.

The mortgagee must establish contact with the borrower using alternative methods including telephone, email or video conference to inform the borrower that HUD will make information available about the status and payment history of the borrower’s loan available to local credit bureaus and prospective lenders, to inform the borrower of other available assistance, and to inform the borrower of names and addresses of HUD officials to contact.

The mortgagee must documents their contact with the borrower.  The waiver does not apply to the face-to-face requirement for the Section 248 insurance program.  The waiver is limited to a 12-month period from the date of issuance.  (FHA Letter 20-20, March 13, 2020.)

Covered California opening enrollment

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In response to COVID-19, effective Friday March 20, Covered California opened the health insurance exchance to any eligible uninsured individuals who need health care coverage through the end of June.  After selecting a plan, coverage will begin on the first of the following month, which means individuals losing job-based coverage will not have a gap in coverage.

Consumers who sign up through CoveredCA.com may find out that they are eligible for Medi-Cal, which they can enroll in online.  Those eligible for Medi-Cal can have coverage that is immediately effective.

The Department of Managed Care and the California Department of Insurance will provide guidance to health plans on the special-enrollment period, which will include off-exchange health plans.

All plans offered through Covered California and Medi-Cal provide telehealth options.  All medically necessary screening and testing for COVID-19 is free of charge.  (Covered California Press Release, March 20, 2020.)

Medi-Cal Managed Care Health Plans COVID-19 screening and testing,pharmacy, telehealth and home health

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In response to COVID-19, the California Department of Health Care Services (DHCS) has issued a reminder to all Medi-Cal managed care health plans (MCPs) regarding existing contractual requirements and state and federal laws to ensure access to medically necessary services in a timely manner.

These provisions include: 1) covering all medically necessary emergency care without prior authorization, 2) complying with utilization review timeframes for approving requests for urgent and non-urgent services 3) ensuring provider networks are adequate to handle an increase in need for services, 4) ensuring members are not liable for balance billing, 4) ensuring 24-hour access to a plan representative with authority to authorize services, 5) offering members and providers the option to use telehealth services to deliver care when medically appropriate.  MCPs must act proactively to ensure members can access all medically necessary screening and testing of COVID-19.   MHPs should work with contracted providers to use telehealth services when medically appropriate.

DHCS also allows reimbursement for virtual communication, which includes brief communication with another practitioner or patient who cannot be physically present.

MCPs must approve transportation requests in a timely manner if a member, who may be infected with COVID-19, needs to be seen in person and requests transportation.  Plans are responsible for determining the appropriate mode of transportation required to meet the members needs, paying special attention to those with urgent needs such as dialysis or chemotherapy.

MCPs must ensure that members are at a facility appropriate to the level of care they require.

MCPs must act proactively to ensure member access to needed prescriptions.  MCPs should 1) cover maintenance medications at a minimum 90 day supply (note that limits certain opioids still apply), 2) covering or waiving any prescription delivery costs MCPs should also waive prior authorization and/or step therapy requirements if the provider recommends the enrollee take a different drug and there is a shortage of any particular prescription drug, 3) approving out of network overrides for beneficiaries who may be temporarily outside the plan service area because of COVID-19, 4) setting refill-too-soon edits for maintenance medications to 75 percent or less to authorize early refills when 75 percent of the prior prescription has been used, 5) expanding pharmacy benefit coverage for all disinfectant solutions and wipes that can be processed through the pharmacy benefits system, and 6) ensuring 24/7/365 call center support for pharmacies, providers and members.

DHCS is allowing flexibility for Health Home Programs services to be conducted in a way that prioritized safety.  DHCS encourages MCPs and their contracted Community-Based Care Management Entities to implement telephone and video call assessments.  DHCS is suspending its current in-person visit requirement until further notice.

DHCS is seeking additional flexibility by exploring options to temporarily waive Medicaid and Children’s Health Insurance Program requirements under Section 1135. DHCS will issue additional guidance if waiver requests are granted. (Department of Health Care Services Memorandum, COVID-19 Screening and Testing, March 6, 2020, updated March 16, 2020.)

COVID-19 screening and testing for commercial health insurance

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The California Department of Insurance (CDI) has issued a directive to all insurers providing commercial health coverage regarding steps to ensure that cost does not interfere with availability of COVID-19 testing.

CDI directs all insurers providing commercial health coverage to: 1) reduce cost-sharing to zero for all medically necessary screening and testing for COVID-19, 2) notify the plan’s contracted providers that the plan is waiving cost-sharing, 3) ensure that the plan’s advice nurse line and customer service representatives are so informed, 4) inform the insurer’s call center staff to advise their insureds to call their provider’s office or advice nurse line for instructions about how to best access care for screening and treatment of COVID-19, and 5) prominently display on their websites that cost-sharing for medically COVID-19 screening and testing is waived.

CDI reminds insurers that they: 1) must cover all medically necessary emergency care without prior authorization, 2) comply with utilization review timeframes for approving requests for urgent and non-urgent services, 3) ensure their provider networks are adequate to handle an increase in need for services and 4) ensure enrollees are not liable for balance billing.

CDI encourages plans to work with contracted providers to use telehealth services when medically appropriate, and to waive prior authorization and/or step therapy requirements if the provider recommends the enrollee take a different drug and there is a shortage of any particular prescription drug.  (CDI Bulletin, COVID-19 Screening and Testing, March 5, 2020.)