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Clarification of remote services allowed in CDCS during the COVID-19 peacetime emergency

Bulletin #20-48-01, Temporary expansion of remote support for home and community-based services (HCBS) waivers (PDF), allows providers to deliver personal assistance remotely. This webpage clarifies which activities may be provided remotely and the documentation required to authorize those activities.

The CDCS personal assistance category includes activities such as caregiver relief, companionship, help with activities of daily living (ADLs) and instrumental activities of daily living (IADLs), mobility and transfer support, and skill building.

If a person receives alternative therapies (i.e. music or art therapy), employment/vocational or day services, training or support for social skills or other skills group training, or behavioral services, these services may be provided remotely when the service can successfully be provided with real-time, two-way communication and the service is comparable with the activities allowed under personal assistance:

  • Caregiver relief
  • Companionship
  • Help with ADLs and IADLs
  • Mobility and transfer support
  • Skill building.


  • A person could continue to receive music or art therapy via remote technology if that will provide relief to the primary caregiver.
  • A person could continue to attend a social or advocacy skills group via remote technology for skill building services.


The lead agency should document communication with the person who receives services and the financial management service (FMS) about approvals for specific services and the comparable activities allowed to be delivered remotely during this time. The lead agency should also indicate “COVID-19 policy direction” in that documentation.

The CDCS plan does not need to be updated specifically for services and supports that were approved before the peacetime emergency that may now be provided remotely. The person and lead agency should continue to follow their standard procedures for approving and verifying services. The FMS provider should follow its existing billing practices by paying for approved services and submitting claims under the service category identified in the plan.

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