PURPOSE:
Effective September 4, 2018, OPWDD issued Administrative Memorandum #2018-09, entitled “Staff
Action Plan Program and Billing Requirements,” describing Staff Action Plan requirements as they
relate to the Life Plan as the Office for People With Developmental Disabilities (OPWDD) transitions
its care management service to the Care Coordination service. This ADM, ADM #2018-09R,
replaces ADM #2018-09 to make certain clarifying revisions. Those revisions are underlined below
and are effective retroactive to September 4, 2018.
When an individual’s ISP is replaced by a Life Plan, the habilitative goals/valued outcomes,
habilitation service provider assigned goals, and individual safeguards/Individual Plan of
Protection (IPOP) is integrated into the Life Plan. The Life Plan is the active document defining
the person-centered habilitative goals/valued outcomes and required individual safeguards/IPOP
needs.
Habilitation providers delivering services reflected in the Life Plan must identify how:
• habilitation staff will assist the individual to achieve his/her defined habilitative
goals/valued outcomes; and
• individual safeguards/IPOP needs identified in the Life Plan will be met.
Habilitation providers accomplish this by creating, developing and implementing a Staff Action
Plan. Individuals must have a Staff Action Plan for each habilitation service they receive. The
overarching protections listed in the individual safeguards/IPOP section identified in the Life
Plan may be further detailed in a Staff Action Plan or internal guidance document created by the
habilitation provider. The Staff Action Plan and/or internal guidance document further details the
individual’s needed safeguards, staff supports, and/or specific/detailed protective oversight
measures to ensure the health and safety of the individual receiving the habilitation service(s). The
Life Plan and/or the Staff Action Plan must specifically reference where the additional detail is
located (e.g., see “Plan of Nursing Services”, see “Behavior Support Plan”, see “Community
Supervision Safeguarding Protocol”).
APPLICABILITY:
During a transition period, July 1, 2018 through December 31, 2019 (“transition period”), both
Individualized Service Plans (ISPs), Life Plans, Habilitation Plans, and Staff Action Plans may be
in effect throughout the Office for People With Developmental Disabilities (OPWDD) service
system. Staff Action Plans are required whether the individual receives care management from a
Managed Care Organization (MCO) or a Care Coordination Organization (CCO) providing Health
Home Care Management/Basic Home and Community-Based Services (HCBS) Plan Support. At
the time of transition to the Life Plan, Habilitation Plans must transition to Staff Action Plans.
Creating and Distributing Staff Action Plans for Individuals New to the OPWDD System
Individuals new to the OPWDD system (i.e., on or after July 1, 2018) do not have ISPs or
habilitation plans in place. Therefore, Staff Action Plans for these individuals must be created
and distributed per the requirements in the “Creating the Staff Action Plan” subsection on page
8. The billing standards requirements apply wholly to these new individuals.
Creating and Distributing Staff Action Plans for Individuals in the OPWDD System