FCASPL 359 (COVID-19 Pandemic Guidance)
Family, Children and Adult Services Procedure Letter No. 359
September 17, 2020
TO: All Family, Children, and Adult Services Manual Holders
FROM: Kimberly Hall, Director
SUBJECT: COVID-19 Pandemic Guidance

This Procedure Letter provides updates to the extension of foster home recertifications, adoption approval dates, assessor training, and CPOE activities. In order to maintain COVID-19 related guidance in one letter, the information from FCASPL 348 and FCASPL 356 has been added to this procedure letter. Some clarifying changes have been made regarding the content brought over from those letters. Those changes have been underlined in this letter so they can be easily found.

Foster Care Recertification and Adoption Update Timeframes

HB 197 of the 133rd Ohio General Assembly included language to allow ODJFS to extend all foster home recertifications and adoption updates. Pursuant to HB 197, ODJFS will be ending the extension of all foster care recertifications and adoption updates scheduled to expire during the pandemic on December 1, 2020. ODJFS and the SACWIS team will continue implementing data fixes to extend affected foster care and adoption spans until December 1, 2020.

Please ensure that all foster care recertifications and adoption updates that were due between March 1, 2020 and December 1, 2020 are completed in SACWIS by December 1, 2020. After December 1, 2020, all timeframes for certifications and approvals will return to normal. Agencies are to be flexible in allowing synchronous and online training options to support the continued education of their foster families. If families were unable to complete training hours due to the reasons documented in the agency’s good cause policy, the recommending agency may recertify the home in accordance with that policy. The family would be required to complete the hours in their next certification period, in addition to the training hours required for that span.

Foster Care and Adoption Assessor Tier I and Tier II Timeframes

The Ohio Child Welfare Training Program has been working very hard to ensure that the prescribed Tier I and Tier II trainings are available in a virtual capacity or a socially distanced physical capacity. Due to the length of time it has taken to transition some of the Tier I and Tier II curriculums to a virtual platform and the continued need for assessors to be able to complete assessor work, we are providing the following guidance:

Any assessors required to complete Tier I or Tier II training between March 1, 2020 and March 1, 2021, will have until March 1, 2021 to complete the relevant Tier training sessions. Assessors are to submit the JFS 01680 to ODJFS as they normally would upon completion of the Tier curriculum. Tier I and Tier II training timelines will resume March 1, 2021.

This extension of Tier I and Tier II timeframes does not apply to ongoing assessor hours that are to be completed every two years once Tier I and Tier II are completed. Those assessors whose six hours of ongoing training were due between March 1, 2020 and December 1, 2020 have until December 1, 2020 to complete the ongoing training. Ongoing training timelines will resume December 1, 2020.

Child Protection Oversight and Evaluation

Prior to COVID-19, ODJFS had initiated Phase 1 of the Child Protection Oversight and Evaluation 12 (CPOE-12) and Technical Assistance Specialists had begun reaching out to those counties scheduled for entrances April-June 2020. However, the office recognized the need to temporarily suspend CPOE-12 activities until October 2020 to allow counties to prioritize the safety and well-being of the children and families under their jurisdiction. In May 2020, the Children’s Bureau released guidance for reviewing cases during the COVID-19 pandemic to ensure children’s safety and permanency. Due to the unforeseen length of the pandemic, the months of the pandemic will not be omitted from CPOE-12. CPOE-12 Phase 1 case reviews will follow this guidance and consider the impact of COVID-19 on case management activities. As with the CFSR case reviews, counties will be asked to provide their COVID-19 policies and discussions, and the reviews will take into consideration county-level policies, guidance and instruction regarding assessments and visitation. Technical Assistance Specialists are in the process of scheduling entrance conferences with those counties previously scheduled.

As indicated in Director Kimberly Hall’s PRACTICE CONSIDERATIONS DURING COVID-19 memo dated 3/16/2020, child protection responsibilities include responding to reports of maltreatment to our most vulnerable citizens. Agencies must still assess safety during all phases of a case including screening, assessment/investigation and ongoing regardless of where children reside. Agencies should review the guidance provided in the memorandum for additional information and as always counties should reach out to their technical assistance specialist directly with any questions or for additional support.

COVID-19 Positive Result Notification

All agencies and substitute care providers are instructed to notify the ODJFS helpdesk at HELP-DESK-OCF@jfs.ohio.gov if any staff, caregiver, household member, or child tests positive for COVID-19 so that ODJFS may provide support and ensure all Department of Health protocols are followed.

Foster Care, Adoption, Kinship Care and Residential Facility Guidance

This guidance is effective until further notice unless explicitly stated below:

Agencies are encouraged to review their own internal policies to see if there are restrictions in place that are beyond what is required by state and federal regulations. If those policies that go beyond state and federal regulations will now cause undue hardship or endanger the health of agency staff, caregivers, children in care, or the general public, it is strongly recommended that agencies consider easing those restrictions at this time.

Foster Parent Capacity:

  • If the custodial and recommending agency have a critical need to exceed the maximum of ten children in a home as stated in 5101:2-5-32 (C) they should submit those requests with detailed information to the OFC Helpdesk at HELP-DESK-OCF@jfs.ohio.gov. Our office will respond as timely as possible to such requests.

Initial Certification or Approval for Foster Care, Adoption, or Kinship Care (as applicable to each area):

  • Pre-service training hours cannot be waived. However, the training methods can be flexible during this time. Trainings can be delivered via live synchronous training and/or through Foster Parent College for preservice, up to the minimum hours required for their certification type. Regardless of which training method is used, agencies are still required to ensure that all training topics and hours are met. Guidance is available from each OCWTP regional training center regarding Foster Parent College preservice hours and topics. Training for adoptive-only families may still be waived, except for the 3 hours of culture training.
  • CPR and First Aid certification may be completed online without certification, pursuant to the recent model standards changes.
  • Live synchronous training will be eligible for foster parent stipends and reimbursements and agency allowance. Online training is eligible for foster parent stipends and reimbursements but is not eligible for agency allowance.
  • If private agencies decide to amend the trainings offered for their families, they shall document these changes in their training plan. The revised training plans do not need to be submitted to ODJFS at this time.
  • Criminal background checks are still required for all potential caregivers and adult household members. If families have the appropriate supplies, they may print the fingerprint form and complete their own fingerprints with an ink pad, then mail it in to BCI. The form and address can be found here: https://www.ohioattorneygeneral.gov/​Files/​Forms/​Forms-for-BCI-Criminal-Records-and-Background-Chec/​Background-Check-Forms/​BCI-fingerprint-card.aspx. BCI has also stated that several locations are still completing Webchecks. Recommending agencies and families are urged to use this link to locate Webcheck services by county or zip code if unable to complete the fingerprints manually at home: https://www.ohioattorneygeneral.gov/​Business/​Services-for-Business/​WebCheck/​Webcheck-Community-Listing.
  • If a safety audit has not been conducted yet for an initial homestudy or kinship assessment, the worker must take appropriate precautions with social distancing, gloves, not touching household items, etc. and complete the safety audit/physical check of the home as quickly as possible and leave the home.
  • As interviews are to be completed face-to-face, the worker may do these via Skype, Facetime, or other video conferencing equipment so that in-person contact is kept to a minimum as much as possible.
  • Medical statements do not currently require contact with a physician. Families can use whatever means available to have physicians complete the forms, such as email, fax, mail, etc. If a physician requires a visit, this may be done via telehealth as well.
  • Fire inspections are required prior to initial certification. Please request the fire inspection as soon as possible. The inspectors will complete them as they are able. Many fire inspectors have moved to complete these via video-conferencing technology.
  • Well water inspections are required unless there is another plan for water in the home. If the local health department is unable to complete the inspections, the families may use bottled or filtered water as an alternative to the inspection.
  • Other requirements that can be done electronically, such as abuse/neglect checks, sex offender checks, financial forms, etc., should be conducted in this manner.

Amendments for Foster or Adoptive Homes:

  • Please review guidance provided above for any amendment requirements applicable to the change that has occurred (i.e. address change, new household member, etc.) Any interviews may be conducted via Skype, Facetime, or other video conferencing equipment.

Recertifications and Updates for Foster and Adoptive Homes:

  • If foster parents would like to complete ongoing training requirements during this time, they may do so via live synchronous or online training up to the minimum hours of training required for their certification type. Agencies are to be flexible in allowing synchronous and online training to occur to support the continued education of their foster families.
  • CPR and First Aid certification may be completed online without certification, pursuant to the recent model standards changes.
  • Live synchronous training will be eligible for foster parent stipends and reimbursements and agency allowance. Online training is eligible for foster parent stipends and reimbursements but is not eligible for agency allowance.
  • If private agencies decide to amend the trainings offered for their families, they shall document these changes in their training plan. The revised training plans do not need to be submitted to ODJFS at this time.

Documentation:

When a recommending agency chooses an alternative requirement identified above, it must be documented in a SACWIS provider activity log. ODJFS recommends starting the activity log narrative with “COVID-19”.

Ratio Residential Requirements:

  • Child to staff ratios for Children’s Residential Centers (CRCs) may be increased from 1:10 to 1:15 during the emergency.
  • Ratios for infants and toddlers in residential parenting facilities may increase from 1:5 to 1:7 during the emergency.
  • If residential facilities increase staffing ratios as permitted above, the facilities shall notify the OFC Helpdesk at HELP-DESK-OCF@jfs.ohio.gov.

Staff Residential Requirements:

1.All required background checks have been received and reviewed.

2.Staff have completed the initial orientation required by rule 5101:2-9-03.

3.CPR and First Aid training has been completed. It may be completed online without certification at this time. Certification shall be completed within 90 days after the emergency ends.

  • The additional twenty hours of first year training are still required; however, they no longer must be completed prior to working alone with children.
  • If staff CPR and First Aid certification is due to expire, the training may be completed online without certification during this time. Certification shall be completed within 90 days after the emergency ends.
  • One person certified in CPR and First Aid must still be on duty in a living unit at all times.

Facility Residential Requirements:

  • If a residential facility is not able to obtain a well water inspection, the facility may use bottled or filtered water as an alternative to the inspection during the emergency.
  • Residential facilities shall do their best to meet the current requirements of rule 5101:2-9-20 regarding food and nutrition. If any foods are not available because of a shortage in the community, the facility shall still provide a nutritious meal to all residents.

INSTRUCTIONS:

The following chart depicts what materials should be deleted from the Family, Children and Adult Services Manual (FCASM) and what materials are to be inserted in the FCASM.

LOCATION

REMOVE AND FILE

AS OBSOLETE

INSERT/REPLACEMENT
PROCEDURE LETTERS FCASPL No. 348 and 356 FCASPL No. 359