Individuals certifying Ohio assisted living communities should receive additional training to clarify confusion over “particularly challenging areas” of Ohio’s assisted living waiver for memory care rules, according to LeadingAge Ohio.
The association made the recommendation earlier this month as part of a public comment period reopened by the Ohio Department of Aging for proposed amendments to the state’s assisted living service waiver.
In an April 2 response, LeadingAge Ohio indicated that it has fielded questions from members who have cited “confusing” questions from certifying staff from Area Agencies on Aging, saying that such staff need additional training in several areas, including provider recommendation requirements, unit designation, staffing guidance and call light response time, and basic service and memory care.
Specifically, one area where LeadingAge Ohio said that confusion exists is over whether a primary care provider recommendation is required for memory care. The organization also is seeking clarification on the types of documentation providers can offer when being evaluated for compliance with staffing and call light response time. And LeadingAge Ohio also is looking to clarify the meaning of language changes related to basic service and memory care services that conflict with billing structures.
Additionally, LeadingAge Ohio is seeking language changes related to critical access payments that would make such payments more responsive to census fluctuations over small periods of time.
A spokeswoman said that the organization has had “constructive conversations” with the state about its concerns, including recommendations for particularly challenging areas of the rule.”
Rules reflect ‘significant changes’
Last fall, the Ohio Department of Aging published draft rules that revise the certification criteria for the state’s assisted living waiver. At that time, LeadingAge Ohio said that the draft rules contained “significant” changes.”
The rules outlined two different levels of provider certification, with new requirements for any assisted living community seeking an add-on payment for memory care.
At the time, LeadingAge Ohio expressed initial concerns regarding the “expansive” nature of some of the memory care requirements, noting that many of them are more restrictive than existing rules applying to higher levels of care, including care provided at nursing facilities.
Among the proposed memory care requirements, communities would have to have a “mission statement” that describes how an assisted living community’s memory care offering differs from its basic assisted living service. The proposal also would require that communities arrange at least three therapeutic, social or recreational activities per day, giving consideration to each resident’s preferences and needs and ensuring safe access to outdoor space for all residents.
The proposed rule also would require that assisted living communities offering memory care have a medical director on staff and have a registered nurse on staff at all hours, and it would establish minimum staffing ratios and require staff members to respond to a resident call system alert within 10 minutes of an alert. It also would implement minimum staff member training requirements, including dementia care training.
