COFAR blog

As the number of people infected with the coronavirus continues to grow in Massachusetts, the Department of Developmental Services (DDS) appears to lack a clear and consistent set of policies and plans for protecting residents in its group homes and other residential facilities.

Instead, there appears to be a patchwork of statements and sometimes contradictory policies on the DDS coronavirus website page.

We are concerned that to the extent DDS has developed policies on how residents should be cared for and what precautions should be taken by staff, current protocols will be inadequate to protect residents of any DDS-run or corporate provider-run facility should one or more of the residents become exposed to or infected by the virus.

At least one set of guidelines sent out by DDS to providers this past weekend appears to imply that residents of group homes must be removed from those facilities if even one resident becomes infected. But DDS appears to have no plan for where those residents would be taken.

If residents in several homes become infected, the system could become quickly overwhelmed.

In phone contacts on Wednesday (March 25), DDS officials acknowledged the Department has no long-term plan for relocating infected residents from their residences if the pandemic becomes worse.

We are recommending to DDS that a single, comprehensive plan be developed immediately to address all contingencies in the Department’s residential system, including the possibility of removing infected residents from group homes and placing them in DDS-run hospital settings. That might involve re-purposing closed day program facilities or finding and re-purposing available space in the state’s two remaining Intermediate Care Facilities (ICFs).

We have already heard of instances in which individual providers have opened new group homes or re-purposed existing facilities to be able to respond to those contingencies.

Current guidance documents are contradictory and potentially inadequate 

DDS appears to have been relying on a guidance document from the Department of Public Health (DPH) to cover COVID-19-related precautions and procedures in residential programs in the DDS system.

The March 16 DPH guidelines state, among other things, that patients with known or suspected COVID-19 should be cared for in a single-person room with the door closed.

But COFAR Board President Thomas J. Frain said he is concerned that most group homes are too small to ensure that an infected or ill resident could be effectively isolated from the other residents of the residence.

Meanwhile, a second guidance document, dated March 20, which DDS informed Frain had been sent to all providers this past weekend, appears to imply that any resident of a “household”-sized facility who is suspected of even having had “close contact” with someone known to have the virus should be removed from the residence for 14 days.

Group homes are effectively households, Frain said. If one person does test positive for the virus, everyone else in the residence will essentially have had close contact with them. So the second directive would imply that if one person is exposed or is sick with the virus, everyone would need to be quarantined, meaning they would have to be taken somewhere else for 14 days.

Frain maintained that group homes, which often utilize shared bathrooms, are not large enough to isolate an ill resident and protect other residents from becoming infected by the first resident or by infected staff.

The problem is compounded by the fact that DDS has no plans for how to remove and quarantine infected residents safely, promising only to develop them in the future.

High-level advocacy needed for persons with intellectual and developmental disabilities

COFAR stressed to DDS officials the need to advocate on behalf of DDS clients and their families with Health and Human Services Secretary Marylou Sudders and with Governor Baker. “These most vulnerable members of our society have many competing interests from other populations and agencies, but DDS residents cannot self-advocate,” COFAR Executive Director Colleen M. Lutkevich said.

Lutkevich maintained that the lack of planning and advocacy extends to DDS clients in settings other than group homes such as adult foster care and staffed apartments, and even to individuals living at home with their families. “If a person lives alone in an apartment, and even if DDS staff checks on them – what happens when that person becomes ill?” Lutkevich asked.

COFAR suggests repurposing of available facilities

COFAR is urging DDS to require each provider to develop a plan to remove and relocate residents if group homes are forced to close due to infection and quarantine. Those plans could include the re-purposing of currently closed day programs and their staffs, empty quarters or buildings at ICFs, and other appropriate and available locations.  Several providers are already beginning to work on this, and their models of re-purposing facilities could be shared with other providers.

In addition:

• DDS and the Baker administration should seek out federal disaster assistance for help with relocation and care of infected group home and other facility residents.
• Ongoing staff training is needed, particularly if day program staff are retrained to help care for ill residents.

Single set of guidelines needed

We think all of the plans described above need to be part of a single, comprehensive set of guidelines that should be developed for all of DDS’s residential facilities, both state and corporate-provider-run, during the pandemic.  That comprehensive policy document should be communicated in writing to all facility managers.

A primary function of DDS is to make sure its residents are protected, whether in a state-operated group home, a corporate-operated group home or an ICF. DDS regulations define a “serious risk of harm” as “a significant exposure to serious physical injury or serious emotional injury.”

DDS’s current policies do not inspire confidence that the department is currently able, in this ongoing pandemic, to meet the standards for protection and safety that are codified in its statute and regulations.