Self-Direction Guidance for Providers March 10, 2022
Page 47 of 66
Fiscal Intermediary Directed General Employee Orientation, Refresher, and
Classroom/Seminar Training
This is training and instruction provided to all self-hired staff who are co-employed by
the participant and the FI agency on professional, health, safety, and welfare skills,
procedures, and standards. It includes all direct support professional training
mandated by OPWDD or by the FI agency itself.
Billable Charges: Employee time spent receiving employer-mandated training
typically constitutes "time worked" and should be paid as such. Although
employee training time does not represent billable service time, the employment
costs (wages + fringe assessment) associated with such training do represent a
reimbursable cost of delivering the self-hired service. As such, training-related
employment costs may be included in the billed service charges for the service
date the employee training is attended. If there were no claimable service units
for the person on that particular day (e.g., all of the person's self-hired
community habilitation staff attended training that day, there was no substitute
staff, and, therefore, the person did not receive any billable community
habilitation service units that day), the training-related employment costs may be
added to the regular charges on the next day claimable service units were
delivered. Training should be scheduled and paced to minimize the potential of
exceeding the effective reimbursement rate (ERR) caps (see Chapter 16
Preparing Claims to Medicaid for Self-Hired Services) in any billing cycle.
Billable Service Units: Since the staff receiving training renders no habilitation
or respite services, this form of employee training will not yield billable service
units.
Substitute Staff: During the planning process, the person and their Circle of
Support should determine whether substitute staff will be required when regular
self-hired staff attend training. When substitute staff is required, the cost should
be included in the person's budget. This may be accomplished by either
budgeting additional staff hours for self-hired workers who will cover the trainee's
absence or adding Agency Supported or Direct Provider Purchased services to
the budget.
Other Costs: The FI agency is responsible for all other costs of such training
using funds derived from its monthly administrative fee. This includes the wages,
fees, and/or reimbursed expenses of the trainer or instructor, costs of all
instructional materials and their reproduction, facility costs, lodging, refreshments
and meals. Such costs may not be included among the billable charges for self-
hired service itself.