8.09 – Open Door Adult Day Services

PURPOSE

The purpose of this policy is to establish agency standards for the safe, person-centered, community-integrated, and compliant provision of:

1. Adult Day Support (ADS);
2. Vocational Habilitation (VH); and
3. Non-Medical Transportation (NMT).

Services shall be provided in accordance with each individual’s authorized Individual Service Plan (ISP), applicable Ohio Department of Developmental Disabilities (DODD) requirements, Ohio Department of Medicaid requirements, applicable federal Medicaid Home and Community-Based Services requirements, and all other applicable federal, state, and local laws and regulations.

The agency shall provide services in a manner that promotes individual choice, dignity, privacy, independence, self-direction, community membership, meaningful relationships, health, safety, and achievement of outcomes identified in the individual’s ISP.

This policy shall be administered consistent with applicable requirements, including:

• OAC 5123-9-17 — Adult Day Support;
• OAC 5123-9-14 — Vocational Habilitation;
• OAC 5123-9-18 — Non-Medical Transportation;
• OAC 5123-9-19 — General Requirements for Adult Day Support, Employment Services, Non-Medical Transportation, and Vocational Habilitation;
• OAC 5123-4-02 — Individual Service Plans;
• OAC 5123-2-08 — Provider Certification;
• OAC 5123-6 and applicable nursing/medication rules when health-related activities or medication assistance are provided;
• Applicable Ohio Department of Medicaid requirements; and
• Applicable federal HCBS requirements.

The agency shall follow the most current applicable version of each rule. If this policy conflicts with an applicable law, rule, waiver requirement, or Medicaid requirement, the applicable law or rule shall control and the agency shall revise this policy as necessary.

PERSON-CENTERED SERVICE DELIVERY

All services shall be provided in accordance with the individual’s person-centered ISP.

Staff shall:

1. Know the individual’s authorized services and identified outcomes.
2. Respect the individual’s preferences, strengths, abilities, interests, culture, communication style, and desired relationships.
3. Provide opportunities for meaningful choice.
4. Encourage the individual to make decisions concerning daily activities, schedules, environments, and relationships.
5. Support independence rather than unnecessarily performing tasks for the individual.
6. Use natural supports whenever appropriate.
7. Protect privacy, dignity, and confidentiality.
8. Prohibit coercion, intimidation, abuse, neglect, exploitation, and unauthorized restraint.
9. Report incidents in accordance with agency policy and applicable DODD requirements.
10. Coordinate services to avoid duplication or conflicting supports.

ADS must be delivered pursuant to a person-centered ISP and coordinated with the other services and supports identified in that ISP. Ohio Laws

ADULT DAY SUPPORT

A. Purpose of Adult Day Support

Adult Day Support is intended to provide regularly scheduled activities and supports that assist an individual with acquiring, retaining, or improving self-help, socialization, adaptive, and community-living skills.

ADS shall foster:

• Independence;
• Community membership;
• Meaningful relationships;
• Self-direction;
• Self-advocacy;
• Personal choice;
• Problem-solving;
• Social development; and
• Maximum potential consistent with the individual’s abilities and preferences.

B. Facility-Based Adult Day Support

When ADS is provided in a facility or other non-residential setting, the setting shall be separate from an individual’s home.

Facility-based activities shall be individualized and shall not consist solely of custodial care, passive supervision, or activities selected for staff convenience.

Activities may include, when identified as appropriate to the individual’s needs and ISP:

• Daily living skill development;
• Communication skill development;
• Mobility and adaptive skill development;
• Self-advocacy;
• Self-determination;
• Social skill development;
• Problem-solving;
• Community preparation;
• Money-management skill development;
• Safety skill development;
• Relationship development;
• Skill reinforcement;
• Therapeutic recreation or leisure activities when permitted under the applicable rule; and
• Personal care or health-related supports that are permitted under applicable law and rule.

Staff shall continually seek opportunities to transfer skills developed in the facility to integrated community environments.

C. Integrated Community ADS

ADS shall be delivered in a manner that supports full access to the greater community to the same degree of access available to individuals who do not receive HCBS.

Staff shall:

1. Develop activities around the individual’s interests, preferences, strengths, skills, talents, and outcomes.
2. Offer meaningful choices rather than predetermined activities.
3. Support participation in ordinary community locations.
4. Promote interaction with people with and without disabilities.
5. Encourage natural relationships and community connections.
6. Avoid unnecessary segregation or isolation.
7. Support the individual’s ability to independently access community activities whenever possible.
8. Document the individual’s participation, skill development, and response to the service.

Community activities shall not be selected solely for staff convenience.

The agency shall not use a community location merely as a change of scenery while continuing to provide a congregate program that does not promote individual participation or skill development.

D. Individual Choice

Individuals shall have meaningful opportunities to choose:

• Activities;
• Community locations;
• Schedules when reasonably possible;
• People with whom they interact;
• Recreational and leisure activities;
• Learning opportunities; and
• Other aspects of service delivery consistent with the ISP.

Staff shall document significant choices when necessary to demonstrate that person-centered service delivery occurred.

E. Privacy

Individuals shall have reasonable access to privacy.

Areas used for toileting shall provide sufficient privacy. Individuals who elect to disengage from activities or be alone on occasion shall have access to an appropriate private area.

F. Health and Safety

The agency shall maintain the physical environment in compliance with applicable requirements.

Facility-based ADS locations shall maintain required fire and carbon-monoxide safety equipment and emergency procedures. Under OAC 5123-9-17, smoke and carbon-monoxide detectors must be tested at least monthly, fire extinguishers serviced at least annually, and the provider must conduct at least three fire drills and one tornado drill during a twelve-month period. Ohio Laws

The agency shall maintain documentation of required inspections, testing, servicing, drills, and emergency-preparedness activities.

G. Virtual ADS

Virtual ADS may be provided only when permitted by the individual’s ISP and applicable rule.

Virtual services shall not isolate an individual from the community or prevent interaction with people with or without disabilities.

Virtual ADS shall not be used to provide services that the applicable rule requires to be provided in person, including applicable personal-care and health-related activities. Ohio Laws

VI. VOCATIONAL HABILITATION

A. Purpose

Vocational Habilitation shall be provided to assist individuals in developing, maintaining, or improving skills associated with vocational and employment-related outcomes.

VH shall be individualized and based upon the individual’s interests, abilities, preferences, strengths, needs, and ISP outcomes.

B. Service Delivery

Staff shall provide active instruction, modeling, prompting, coaching, reinforcement, and other appropriate habilitative supports.

Services may include:

• Work-related skill development;
• Workplace behavior;
• Communication;
• Following directions;
• Time-management skills;
• Task completion;
• Workplace safety;
• Appropriate workplace interactions;
• Transportation skills related to employment;
• Problem-solving;
• Job-related independence;
• Work stamina;
• Community employment skills; and
• Other vocational outcomes identified in the ISP.

C. Integrated Vocational Experiences

When vocational services are provided in community or workplace settings, staff shall support meaningful participation and skill development.

Staff shall avoid performing work tasks for an individual when the purpose of the service is to teach the individual to perform those tasks.

The agency shall coordinate VH with career planning, employment services, ADS, NMT, and other supports to avoid duplication.

D. Documentation

VH documentation shall identify:

• The vocational outcome addressed;
• The activity or skill addressed;
• The support or instruction provided;
• The individual’s participation;
• Progress or response;
• Any barriers identified; and
• Follow-up or changes needed.

Documentation shall accurately distinguish VH from ADS and other services.

NON-MEDICAL TRANSPORTATION

A. Purpose

NMT shall provide authorized transportation to and from locations permitted under applicable Ohio rules, including employment, ADS, career planning, group employment support, individual employment support, VH, volunteer activities, post-secondary education, internships, practicums, and qualifying transfer/drop-off locations. Ohio Laws

NMT shall be provided only when authorized and consistent with the individual’s ISP.

B. Driver Qualifications

The agency shall ensure that every NMT driver:

1. Holds a valid driver’s license as required by Ohio law.
2. Is covered by valid liability insurance as required by applicable law.
3. Meets agency driver qualifications.
4. Has an acceptable driving record.
5. Immediately reports license suspension, revocation, or accumulation of six or more points.
6. Completes required agency transportation-safety training.
7. Complies with all applicable vehicle and passenger-safety requirements.

For an agency NMT provider, Ohio’s current rule requires a BMV driving record at initial employment and at least every three years thereafter; an individual with six or more points may not provide NMT. Ohio Laws

C. Vehicle Requirements

The agency shall maintain vehicles in safe operating condition.

When applicable under OAC 5123-9-18, vehicles shall have:

• Secure storage for removable equipment and passenger property;
• A two-way communication system;
• A securely mounted fire extinguisher;
• A securely mounted emergency first-aid kit;
• Properly functioning lights;
• Windshield washer/wipers;
• Emergency equipment;
• Mirrors;
• Horn;
• Tires; and
• Brakes.

Required daily vehicle inspections shall be completed by the first driver using the vehicle and before transporting an individual. Annual inspections shall be completed when required by the rule. Ohio Laws

D. Wheelchair and Mobility Equipment

When a modified vehicle is used, required wheelchair securement systems, ramps, lifts, and other accessibility equipment shall be maintained in safe working condition.

The driver shall inspect applicable equipment before transporting an individual who uses a wheelchair or mobility device.

E. Passenger Safety

Drivers shall:

• Require appropriate seat-belt use;
• Follow safe-driving practices;
• Never transport more individuals than the vehicle is designed and authorized to carry;
• Never leave an individual unattended in a manner that creates a health or safety risk;
• Follow the individual’s transportation-related ISP requirements;
• Maintain appropriate supervision; and
• Follow emergency procedures in the event of an accident, breakdown, medical emergency, severe weather, or other emergency.

F. NMT and Concurrent Billing

When NMT is billed at the per-trip rate, the agency shall not bill ADS, VH, or other specified services during the same time period as the transportation service.

When NMT is billed at the per-mile rate, applicable rules may permit simultaneous billing of ADS or VH when the individual is in the vehicle and the requirements of OAC 5123-9-18 are satisfied.

Billing staff shall verify the applicable billing method before submitting a claim. Ohio Laws

SERVICE DOCUMENTATION

Documentation shall be completed contemporaneously with service delivery and shall accurately disclose the nature and extent of services provided.

Documentation shall never be created solely for the purpose of supporting a claim for a service that was not provided.

A. ADS and VH Documentation

Documentation shall include, as applicable:

• Individual’s name;
• Date;
• Service provided;
• Location;
• Beginning and ending time or applicable billing unit;
• Staff providing the service;
• ISP outcome or skill addressed;
• Description of the actual support provided;
• Individual’s participation and response;
• Progress toward the identified outcome;
• Relevant health or safety information;
• Required staff signature or electronic authentication.

B. NMT Documentation

NMT documentation shall include all information required by OAC 5123-9-18.

For per-trip or per-mile NMT, documentation includes items such as:

• Mode of transportation;
• Date;
• Vehicle license plate;
• Individual’s name and Medicaid identification number;
• Provider information;
• Origination and destination;
• Start and stop times;
• Driver signature or approved electronic authentication;
• Names of individuals transported; and
• Mileage information when billing per mile.

The current NMT rule specifically identifies these documentation elements as necessary to validate Medicaid payment. Ohio Laws

BILLING

The agency shall submit claims only for services:

1. Authorized through the applicable service plan;
2. Actually delivered;
3. Properly documented;
4. Delivered by qualified staff;
5. Delivered within the authorized service period;
6. Billed using the correct service code and billing unit; and
7. Consistent with applicable rate and billing requirements.

The agency shall not:

• Bill for services not provided;
• Bill duplicate services;
• Alter documentation to support an inaccurate claim;
• Bill services outside the individual’s authorization;
• Bill services during prohibited overlapping periods; or
• Allow staff convenience to determine the service code or billing category.

ADS daily and fifteen-minute billing requirements shall be followed exactly as established in OAC 5123-9-17. For example, the daily ADS billing unit has specific five-to-seven-hour and other eligibility conditions, while fifteen-minute billing applies in specified circumstances, including certain multiple-mode and virtual-service situations. Ohio Laws

STAFFING

The agency shall maintain sufficient staffing to:

• Protect individual health and safety;
• Implement each individual’s ISP;
• Provide the authorized service;
• Support achievement of identified outcomes;
• Provide appropriate supervision;
• Respond to emergencies; and
• Meet applicable staffing and group-size requirements.

No more than sixteen individuals may receive ADS, group employment support, or VH in one group, regardless of funding source, subject to any more restrictive requirement applicable to the service or individual. Ohio Laws

The agency shall not schedule staff at levels that prevent effective implementation of individual outcomes.

INDIVIDUAL RIGHTS AND GRIEVANCES

Individuals receiving services shall be informed of their rights and shall have opportunities to express concerns regarding services without retaliation.

An individual may request changes to services, staff, activities, schedules, or other aspects of service delivery through the appropriate person-centered planning process.

Staff shall immediately report allegations of abuse, neglect, exploitation, rights violations, or retaliation according to agency procedures.

Adult Day Array Service/Locations:

A. Career and Activity Center

Consistent with 5123:2-9-17, the Career Activity Center (CAC) is dedicated to inspiring life journeys. CAC offers personalized plans and services through:

• Assisting individuals on a path to employment.
• Finding, obtaining, and providing supports for employment in community settings.
• Providing learning and work experiences.
• Providing various volunteer opportunities in community.
• Building community memberships and relationships.
• Creating connections for friendships.
• Establishing partnerships in the community.
• Providing and supporting access to integrated community programs though events, civic groups, volunteer opportunities, activities, and clubs.
• Developing new skills, experiences, and a sense of independence though:
  • Exploring creativity and art
  • Theatre and performing arts
  • Enjoying a multi-sensory experience in the sensory space
  • Developing a “green thumb” through nature activities in the greenhouse and garden
  • Cooking classes
  • Playing sports and games in the multi-purpose gymnasium
  • Learning about exercise in the movement space
  • Enhancing cooking skills in the kitchen
  • Referrals for employment services, OOD services

B. Open Door Art Studio

Open Door Art Studio (ODAS) is a visual arts studio located in Grandview that offers a program of adult day support with an emphasis on art as a interest/hobby, skill development, and/or careers in community arts. ODAS provides artists an opportunity to collaborate with both professional and volunteer artists in the community and in the gallery. Each artist is provided with individualized education and mentoring to further develop their skills and help them reach their outcomes based on their choices and preferences. The artist exhibit arts in multiple locations throughout the community, participate in art competitions, lead classes at local art locations, and engage with art collectives throughout Ohio.

C. CCHS Open Door at UCO

Open Door in Union County is proud to offer two unique, innovative adult day service programs designed to inspire the life journeys of individuals with disabilities in the greater Marysville area.

Open Door at UCO Industries, Inc.

• Individuals work as an employee of UCO Industries and must meet their workplace requirements and expectations. Open Door provides Transportation, nursing, and on-the-job supports while individuals work on production lines or tables supporting the Tier I Honda Supplier.

On-the-Go in UCO

• Open Door in Union County is proud to offer individuals a fully community-based choice for their adult day program needs. Participants in our On-the-Go models spend 100% of their time immersed and engaged in the community doing experiences to meet their outcomes based on interests, preferences, and choices.

D. Career/Employment Referrals

At Open Door, We believe that integrated community employment is mutually beneficial, enhances diversity and inclusion, ensures financial security, and provides stability for today’s ever-changing workplaces. We assist individuals to connect with employment services providers and OOD for career search, job development, coaching, and follow-through. Many individuals that we serve work in the community and other settings and attend ADS on days that they do not work. Open Door cooperates with all employment needs and works with these teams to ensure individual has choice.

HCBS Settings Requirements

The “ODM Settings Rule” refers to policies governing Home and Community-Based Services (HCBS) in Ohio, primarily administered by the Ohio Department of Medicaid (ODM) and Ohio Department of Developmental Disabilities (DODD). These policies, derived from a federal Centers for Medicare and Medicaid Services (CMS) rule, ensure that individuals with disabilities receiving HCBS are integrated into their communities and have control over their own lives.  

Purpose

The purpose of this policy is to ensure that all services and supports delivered CCHS dba Open Door comply with the federal HCBS Settings Rule, as implemented by the Ohio Department of Medicaid (ODM) and Ohio Department of Developmental Disabilities (DODD). This includes delivering services in a manner that supports community integration, independence, and individual choice.

This policy applies to all staff and contractors who provide HCBS services under an ODM/DODD-administered waiver.

Principles of the HCBS Settings Rule

The following principles will guide all service provision:

• Person-Centered Planning: The individual’s service plan will be developed through a person-centered process that includes the individual and their chosen representatives, focuses on the individual’s goals and preferences, and is accessible to them.
• Community Integration: Services will be delivered in settings that promote access to the greater community, including opportunities for competitive integrated employment, community life, and access to services available to the general public.
• Individual Choice and Autonomy: Individuals have the right to make their own life choices, including choosing their home and roommates, their daily schedules and activities, and who provides their services.
• Individual Rights: Settings will ensure an individual’s rights to privacy, dignity, respect, and freedom from coercion and restraint.
• Privacy and Personal Freedom: Individuals have the right to privacy in their living unit, including a lockable door, and the freedom to furnish their own space.
• Flexibility and Access: Settings will not regiment individual schedules and will allow for choices in daily activities, meals, and visitors.  

Non-Residential Settings (e.g., Adult Day Services)

For all non-residential settings, the following conditions must be met:

• Community Integration: All services must support engagement in integrated community life, with activities available to the public.
• Individual Choice in Activities: Individuals must have input into the activities and experiences available to them.
• Meaningful Outcomes: Services must be designed to achieve the individual’s desired outcomes and support their full community participation.

Modifications and Restrictions

• Any modification of the conditions described above (e.g., restricting an individual’s access to a certain area) must be justified by a specific assessed need and documented in the person-centered service plan.
• The modification must be based on a documented risk to the individual or others and must be the least restrictive intervention possible.
• All modifications must include a positive support strategy to address the underlying issue.

Staff Training and Compliance

• All staff will be trained on the principles of the HCBS Settings Rule and ADS and the specific requirements of this policy.
• Training will cover individual rights, community integration, person-centered practices, and positive behavior support.

Individual Rights and Appeals

• Individuals and their families can file a grievance at any time through calling the incident hotline 614-701-6993 or via electronic form on website.  They will be investigated according to grievance/compliant policy.
• Individuals and families will be surveyed on satisfaction of services; results routed to team for any follow-up needs.  

Responding to concerns that may affect participation in Day Service programm

This policy establishes a team-centered process for responding to health, safety, behavioral, illness-related, bed bug, or other concerns that may affect a person’s continued participation in the day program. Service changes, added supports, temporary interruptions, or exclusion must be considered and documented through the planning-team process described below.

• Open Door obligation: Will remain willing and able to serve while working with the team to solve challenges. Open Door cannot exclude anyone’s participation unilaterally.
• County Board / SSA obligation: Convene the team promptly. Ensure supports are explored before any exclusion is considered.
• Team obligation: Make decisions about service changes, added supports, or, only as a last resort, exclusion. Document all decisions.

Process:

Step 1 – Concern Arises

• A concern may involve aggression, behavior, illness, bed bugs, or another issue occurring at the day program.
• Open Door staff document the incident immediately.
• Open Door may NOT suspend or exclude the individual unilaterally. The provider may temporarily cease bed bug entry/transport for the limited two-day observation period while the team is notified. If the two-day period is being implemented, the team must be notified as soon as possible.
• The provider must notify the SSA in writing within 24 hours.

Step 2 – SSA Convenes Team

• The SSA convenes an emergency planning-team meeting within 72 hours of provider notification.
• All team members are notified, including the individual, guardian, provider, residential provider, SSA, and others as relevant.
• Open Door participates and presents specific concerns, documentation, and support needs.
• The team reviews the person’s health, safety, and service data.

Step 3 – Team Assesses and Plans

• The team identifies additional supports, services, or modifications that could allow continued attendance.
• Consider increased staffing ratios, behavior support, medical consultation, environmental modifications, and schedule changes.
• Address the health and safety of ALL individuals in the program, not just the individual whose situation prompted the meeting.
• Open Door communicates what it can and cannot accommodate.

Step 4 – Team Decides: Two Paths

• Path A – Supports are identified: The team authorizes a plan; the provider implements the plan with new resources.
• Path B – The team determines no realistic support can make continued attendance safe: The team, not Open Door alone, authorizes exclusion or transition.
• Open Door cannot make this call alone. The County Board cannot make this call alone.
• All decisions are documented in the ISP or meeting notes and signed/acknowledged by the team.

Step 5 – Outcome and Accountability

• Path A – The individual returns/continues with enhanced supports; the team monitors progress and reconvenes as needed.
• Path B – The provider issues formal 30-day notice; the SSA initiates immediate transition planning; full services continue through day 30.
• If the provider excludes the individual WITHOUT team authorization, the team follows the DODD complaint process, including the Office of Provider Standards & Review.
• The residential provider notifies the SSA if an absence is unexplained or the individual declines support calls.

ADS Provider (Open Door) Must

• Attempt to serve; document all incidents and concerns in writing.
• Notify the SSA within 24 hours; do not wait to see whether circumstances improve.
• Participate fully in team meetings with specific data and support requests.
• Implement the team-authorized support plan in good faith.
• Continue full services if 30-day notice is issued, with no informal reduction.
• Never suspend, exclude, or reduce service without team authorization.

County Board / SSA Must

• Convene an emergency team meeting within 72 hours of provider notification.
• Facilitate team review of ALL available support options before exclusion or transition is considered.
• Ensure transition planning begins immediately when a 30-day notice is received.
• Investigate and escalate if a provider excludes without team authorization.
• County board does NOT provide provider due process; individual recourse is through the DODD complaint or claim process.

Planning Team Must

• Serve as the sole decision-making body for service changes, increased supports, and exclusion.
• Explore every realistic support option before authorizing exclusion.
• Balance the individual’s right to services with health and safety obligations to all program participants.
• Document all decisions in writing, including ISP updates and meeting notes, or both.
• Set clear timelines for return, monitoring, and follow-up.
• Reconvene if the situation changes or supports are not working.

Documentation and Compliance

All notifications, incident documentation, team discussions, support options considered, decisions, implementation steps, monitoring expectations, transition activities, and follow-up actions must be documented in the individual record and, when applicable, the ISP or meeting notes. The planning team must be able to demonstrate that realistic support options were considered before exclusion or transition was authorized.

Signed by:

Rebecca Sharp Porter
Chief Executive Director

Last Revised: 9/24/2026