Annual Training Requirements in the 6100 Regulations
The Office of Developmental Programs (ODP) provides trainings that meet the requirements of Regulations governing Home and Community Based Services (HCBS).
Frequently Asked Questions
Each annual training topic area (community integration, individual choice, etc.) on MyODP lists multiple courses. Do staff, consultants and contractors need to take all courses in each category for them to be considered trained in that topic area?
Providers and SCOs must ensure that everyone required by regulation take annual training that covers each topic area:
- The application of person-centered practices, community integration, individual choice and assisting individuals to develop and maintain relationships.
- The prevention, detection and reporting of abuse, suspected abuse and alleged abuse in accordance with the Older Adults Protective Services Act (35 P.S. § § 10225.101—10225.5102), the Child Protective Services Law (23 Pa.C.S. § § 6301—6386), the Adult Protective Services Act (35 P.S. § § 10210.101—10210.704) and applicable protective services regulations.
- Individual rights.
- Recognizing and reporting incidents.
- The safe and appropriate use of behavior supports if the person works directly with an individual.
- Implementation of the individual plan if the person provides an HCBS or base-funding service.
People who are required by regulation to complete annual training are not required to complete each course under a topic area on MyODP to be considered trained in that topic area. For example, there are multiple trainings under the category of “person-centered practices.” A person does not have to take all these trainings to be considered trained in person-centered practices.
Providers and SCOs can choose courses in each topic area that are meaningful to trainees and that enable them to implement the topic area while performing their job functions.
The annual training courses on MyODP exceed 24 hours. Do staff, consultants and contractors have to take all the courses on MyODP to fulfill annual training requirements?
People who are required to complete annual training do not need to take all the annual training courses on MyODP to fulfill annual training requirements. Providers and SCOs are responsible for ensuring that people who are required to complete annual training
- Receive training in each topic area required by regulation; and
- Receive the required number of annual training hours stipulated in regulation.
Providers and SCOs can choose courses on MyODP in each topic area that are meaningful to trainees and that enable them to implement the topic area while performing their job functions. Providers and SCOs can also choose to develop their own training or utilize training from other sources (professional associations, College of Direct Supports, etc.) to fulfill annual training requirements. Trainings developed or utilized by providers and SCOs that are not on MyODP do not need to be vetted by ODP prior to utilization. These trainings may be reviewed during licensing inspections, qualifications, the Quality Assessment and Improvement (QA&I) process, or other reviews to ensure that they meet regulatory requirements.
Can providers use the orientation courses on MyODP to fulfill the annual training requirements?
While the orientation sessions can be used to meet annual training requirements, ODP recommends that providers review the Annual Training Catalogue as it has a larger variety of trainings to choose from, is updated on an ongoing basis, and generate certificates of completion that reflect the latest date the course was completed. Ultimately, providers will want to find trainings that are meaningful to trainees and that enable them to implement the training areas required while performing their job functions.
If providers choose to continue to use orientation sessions on MyODP to meet annual training requirements, they will be unable to obtain certificates of completion for each person with the latest date of completion of the training. The original date that the orientation session was completed will remain on the certificate. Providers will be responsible for ensuring that training records are kept in alignment with regulatory requirements. The person completing training can obtain a transcript from MyODP that will show courses taken, including all dates the courses were taken. If one course is taken multiple times by a person, the transcript will show all dates that course was taken.
When provider staff attend an Individual Support Plan meeting, does this meet the requirements of annual training on “implementation of the individual plan if the person provides an HCBS or base-funding service?”
For Supports Coordinators and Targeted Support Managers, facilitation of the Individual Support Plan meeting complies with the requirement for annual training on “implementation of the individual plan if the person provides an HCBS or base-funding service.”
For all other persons required to complete annual training, participating in an Individual Support Plan meeting does not meet this annual training requirement. To ensure that the Individual Support Plan is implemented by the provider per §6100.224, persons responsible for service provision should receive training on their role in implementing the Individual Support Plan, including training on the provider’s implementation plan per 6100.221(g), if applicable. Training must include all knowledge and skills necessary for the health, safety and welfare of the specific individuals served including:
- Recommendations and orders from a health care professional, which include, but are not limited to, safe eating/feeding procedures, respiratory maintenance and treatments, positioning and transferring procedures, skin integrity protocols, and individual-specific emergency procedures;
- Behavior support guidelines and crisis intervention strategies outlined in the individual’s Behavior Support Plan or Crisis Intervention Plan;
- The language and means of communication understood by the individual; and
- An understanding of age-related factors such as interests, preferred activities, and stamina.
Please note that there are additional training criteria required beyond orientation for specific circumstances as outlined in:
- Staff training on the behavior support component of an individual plan (§2380.156, §2390.176, §6100.346, §6400.196, §6500.166)
- Medication administration (§2380.122, §2380.129, §2390.192, §2390.198, §6100.462, §6100.468, §6400.162, §6400.169, §6500.132, §6500.139)
- Support coordination, targeted support management and base-funding support coordination (§6100.802).
Section 6100.143(c)(5) requires training on “the safe and appropriate use of behavior supports if the person works directly with an individual.” What should training in this area cover for Supports Coordinators and Targeted Support Managers? Is this required for staff if an individual does not receive behavior supports?
For Supports Coordinators and Targeted Support Managers, training modules under “Safe Use of Behavior Supports” located on MyODP should be utilized to meet this training requirement.
All persons who implement or manage a Behavior Support Plan must be trained on the positive strategies and/or crisis intervention strategies outlined in the plan. Supports Coordinators and Targeted Support Managers are excluded from this training requirement as they do not directly implement or manage behavioral support plans. For all DSPs who render services to individuals who do not have a Behavior Support Plan, basic competency relating to the appropriate use of behavior supports by DSPs is critical to protect the health and safety of the individuals with an intellectual disability or autism across all service types, provider types and service delivery.
Additionally, in accordance with §6100.346 when a restrictive procedure may be used for an individual, the following is required which would meet the training requirements for §6100.143(c)(5):
- A staff person who implements or manages a behavior support component of an individual plan shall be trained in the use of the specific techniques or procedures that are used.
- If a physical restraint will be used, the staff person who implements or manages the behavior support component of the individual plan shall have experienced the use of the physical restraint directly on the staff person.
- Documentation of the training provided, including the staff persons trained, dates of training, description of training and training source, shall be kept.
Supports Coordinators (waiver and base funded), Targeted Support Managers, and Supports Coordinator supervisors are required to complete additional training within the first year of employment per §6100.802. Has ODP developed training for the topic Human Development Across the Life Span? Do any of the trainings available through the College of Direct Supports meet the expectations for training on this topic?
At this time, Human Development over the Lifespan is not an offered training course by ODP. The courses available through the College of Direct Supports do not meet the requirements for training on Human Development over the Lifespan. It is the responsibility of the Supports Coordination Organization to ensure that Supports Coordinators (waiver and base funded), Targeted Support Managers and Supports Coordinator supervisors are trained in this area either by developing the training material or locating a training opportunity for these positions.
Completion of the ODP SC Orientation curriculum or the AAW Support Coordinator Orientation meet all other training requirements contained in §6100.802:
- Facilitation of person-centered planning;
- Conflict resolution;
- Family dynamics; and
- Cultural diversity.