HCBS Settings Countdown: 371 days

Resources

Updated Tool

Based on our efforts last week to clarify and streamline what needs to be submitted, please see attached an update Policy and Site Evidence Tool with policy request clarifications.  We also have attached a crosswalk between policy and site evidence that reiterates some of our information from last week regarding the amount and types of information to be submitted.

Reminder: Updated Timeframe for submission of policy and site evidence

  • Due to feedback, we have updated the timeframe for submitting policy and site evidence to the following based on the Feb 15 notice of this request:
    • April 20 – sites 1-20 are due to be submitted through the portal (please note – we have moved from an April 16 date due to holidays)
    • May 18 – site​s 21-50 are due May 18;
    • June 15 – sites 51+ are due June 15

Uploading to the HFS Portal Clarification

  • We are asking providers to gather all the evidence for one site and upload it at one time using a zip file. The DDD Notification and Evidence Tool suggests a specific way to name items to upload.
  • You do not have to upload all sites at one time, just all evidence for one site at one time.
  • For organizational policies, please gather all of them and upload them at one time under the agency name and policies.

Feedback on Site Submissions

  • In response to feedback, we are offering the following:  for providers with 20 or more sites that have to be submitted, ​if you submit 5 sites by April 1 we will review and offer feedback on one of the sites.  This will not be the full desk validation process, but we can provide feedback on the submitted documentation.  Sites will be reviewed based on a first come first serve basis.  We would anticipate feedback by April 8.

FAQ Highlight – #21 of the FAQs on the HCBS Compliance Webpage (IDHS: HCBS Provider Toolkit (state.il.us))

  1. What kinds of locks are allowable under the Settings Rule but that also comply with the State Fire Marshal’s regulations?

Per the Office of the State Fire Marshal:

Regarding the option for a lockable front door to their home; have access (through keys, key fobs, codes, key cards and any other devices used to gain access through any door lock mechanism) to their bedroom and/or home. 42 CFR § 441.301 (c) (4) (vi) (B) (1)

(B) Each individual has privacy in their sleeping or living unit:

(1) Units have entrance doors lockable by the individual, with only appropriate staff having keys to doors.

OSFM Considerations

  • All door locking mechanisms and systems for individual rooms and spaces must also comply with NFPA 101 Life Safety Code, Chapter 7 and Chapters 32.2 or 33.2 for small residential board and care.
  • Chapter 7 permits a door to have a locking device provided it allows the door to be easily unlocked / opened from within the room or space for the purpose of egress.
  • A single-cylinder lock utilizing a button pressed into the doorknob to lock from the inside, and when turn the knob to exit the room or space, the door automatically unlocks.
  • This type of lock is allowed to have a key, fob, code pad, keycard, etc. to unlock from the outside the facility or room by individual room occupant and any other authorized persons.
  • This type of lock cannot utilize any key, special tools, or knowledge to unlock from the egress side;
    • Special tools would involve a fob, keycard, etc.
    • Special knowledge would be a code, more than one process to unlock, etc.
  • Locks not meeting NFPA 101, Life Safety Code requirements and not permitted would include:
    • Ordinary double-cylinder locks that require keys on both sides of the door to lock and unlock.
    • Chain locks, slide bolts, hasps mounted on the inside, and other type latches if they cannot be unlocked from outside the door by authorized persons during an emergency.

 

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