OLTL Clarifies When PAS Workers May Transport Patients
In late March, the Office of Long-Term Living (OLTL) issued a new policy clarification discussing when personal assistance services (PAS) workers can transport their clients. The policy clarification highlights the requirements laid out in the Community HealthChoices (CHC) Waiver:
"PAS workers may accompany participants into the community when the need is documented in the participant’s person-centered service plan (PCSP). Costs incurred by the PAS workers while accompanying the participant into the community, such as admission fees, are not reimbursable under the waiver as PAS.
In addition, PAS workers may provide transportation to participants as long as the transportation is associated with the provision of PAS, necessary for the participant to work or engage in the community and documented in the participant’s PCSP.
PAS cannot be used to solely transport a participant as this would be considered Non-Medical Transportation services which are available in the waiver. In order to bill for PAS, the participant must have a need for PAS while in community locations for which transportation is necessary and is documented in the participant’s PCSP. PAS workers may provide and bill for Non-Medical Transportation services, however it may not be billed simultaneously with PAS. The PAS worker providing the non-medical transportation services must meet the state’s provider qualifications for transportation services and be enrolled in Medical Assistance as a transportation provider or enrolled with the applicable CHC-MCO’s non-medical transportation broker."
The policy clarification underscores that PAS workers can provide transportation for their participants while “on the clock,” as long as the transportation is related to the participant’s PAS needs and documented in the service plan. For example, if the participant requires the PAS worker to accompany them into the community to assist with activities of daily living (ADLs) such as walking or toileting, the PAS worker can get paid for the time spent driving. Alternatively, the PAS worker could clock out and bill the time as “non-medical transportation,” assuming they are enrolled as a non-medical transportation provider.
The policy clarification serves as a reminder that CHC Plans can and should be considering transportation time when determining the amount of PAS hour are medically necessary. Participants, for their part, should make sure they discuss their transportation needs with their service coordinator, and that these needs are included in the person-centered service plan (PCSP).
