On Regulatory Challenges to RSP Training & Onboarding
This article is intended to address certain challenges remote supports (RS) providers face with remote support professional (RSP) training and onboarding requirements. Like all other HCBS waiver provider agencies, RS providers are required to fulfill certain obligations and requirements in order to establish compliance and operate in good faith. These regulations are intended to preserve the quality of the services rendered and ensure the continued safety of the individuals served. For the most part, these regulations accomplish their objective. However, the unique RSP work situation poses novel challenges. In this article, CAIRSS will outline two major challenges and propose solutions.
The first challenge arises because of the physical distance between the RSP and the individual. Though RSPs provide real-time support to the individual, they do so remotely. They never have direct contact with the individuals to whom they provide services. (While it is possible that, during the course of a remote support period, backup staff may be dispatched to the home to assist the individual, the remote support professional does not - in the vast majority of cases - simultaneously provide that backup.) What’s more, if a smaller RS provider agency used the same employees as RSPs and backup DSPs, that employee would be appropriately subject to regulations and requirements applicable to DSP staff who have direct contact with the individual. When states introduce RS services, many current training/onboarding regulations and requirements for DSPs are copied over to form RS regulations without careful consideration of the difference between direct and remote support.
For example, Ohio, where remote support has been an active waiver service for ten years, requires RSPs to undergo training for universal precautions such as infection control and disposal of bodily waste.* While it is clear that training is necessary and useful for staff in direct contact with an individual served, it does not apply to staff whose work is entirely remote. This pattern remains with other states, including Missouri. The MO DD Waiver Manual outlines the training requirements for staff performing Personal Assistance services (under which remote support services are billed and regulated).† These requirements include CPR, first aid, and non-violent crisis intervention.‡ All of this training is applicable only to staff who are in direct contact with the individual served, which categorically excludes RSPs.
The enforcement of these regulatory requirements has been understanding, yet inconsistent. RS providers remain subject to auditors’ discretion and understanding of the remote nature of RSP work. Without formal separation of regulations and requirements for DSPs and RSPs, RS providers will continue to face unnecessary challenges as it relates to RSP onboarding and training. Given the national DSP shortage and increased demand for remote supports, these barriers should be removed to allow RS providers to more efficiently onboard new RSPs. Additionally, states working to implement remote supports as a waiver service should understand the difference between direct and remote care, and form regulations in accordance with that knowledge.
The second major challenge for RS providers when it comes to RSP training and onboarding is the interstate nature of service provision. Because RSPs can provide simultaneous support to different individuals remotely, it is often the case that one RSP will, during a given shift, support people from different states. This contrasts with the work of DSPs, which typically occurs within one state, no matter how many individuals the DSP serves in each shift. Because of the variation in location of the different individuals served, RS providers are required to administer training in accordance with several state requirements simultaneously.
While many of these onboarding and training aspects are important and non-duplicative (e.g. training on state-specific incident reporting, some background checks), some are redundant and form unnecessary duplications of time and labor for little or no added gain. To use the examples referenced above, the MO DD Waiver Manual requires “training, procedures, and expectations related to the PA in regards to following and implementing the ISP,” “Training in abuse/neglect… (and) confidentiality,” and “Training in communications skills in understanding and respecting individual choice and direction, cultural and ethnic diversity, personal property and familial and social relationships in handling conflict and complaints.” All three of these training items are represented in the 8-Hour training course supplied by the Ohio DODD. Additional course materials which are duplicative include: rights of people with disabilities, self-determination of the individual, explanation of intellectual and developmental disabilities, roles and responsibilities of RSPs, people-first language, person-centered services, trauma-informed care, protecting the health and welfare of people with I/DD, and community integration.
In practical terms, this duplication of training materials and onboarding requirements means that during the hiring process more time is spent repeating information, testing, and training. This can lead to information overload and fatigue among new RSP hires, prolong the training period, and force more RSPs out of the pipeline before they are able to effectively deliver services. CAIRSS agrees that all the aforementioned information is helpful and necessary for best-practice execution of remote supports, but we also believe that unnecessary redundancy should be avoided where possible. As mentioned earlier, we understand that certain aspects of training and onboarding will always need to be accomplished on a state-by-state basis. Incident reporting remains a prime example, as it varies from state to state. But information about the nature of disabilities, the rights of people with disabilities, person-centered planning, community inclusion, etc., should remain the same among different states. We believe this information can and should be condensed into a state-independent, fully compliant training program which is formally acknowledged by each state that has remote supports as a waiver service.
We also understand that this service is relatively new, and that many states simply imported what was used for DSPs. What we’ve learned through our many years of experience is that these regulations don’t often accommodate these two unique aspects of RSP work, it’s remote and interstate nature. CAIRSS believes that the formation of an interstate consensus on basic elements of RSP work, whether it be a formal adoption of multi-state training or a state’s willingness to accept another state’s trainings as acceptable, would go a long way to eliminate these barriers and allow for improved RSP onboarding and training. This optimization would allow RS providers to accommodate more of the growing demand for remote support services, which would improve outcomes for the people we’re all passionate about serving.
*OAC 5123-9-35(C)(4) referencing OAC 5123:2-2-01(D)(17)(g)
† As of June 2021
‡MO DD Waiver Manual Personal Assistant Training Requirements p82-83