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Developmental Disabilities Provider and Partner Resources

​Engagement and Innovation

  • ODDS is committed to engaging individuals, families, providers, and case management partners to gather feedback on policy or guidance proposals through the Engagement and Innovation site to the greatest extent possible.  
  • Responses to comments and feedback are posted at the Engagement and Innovation Archive .

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Description
4/3/2023COVID-19 Policy Guide

​Policies and resources for ODDS, case management entities, and provider staff related to developmental disability services during the COVID-19 pandemic.

3/23/2023Temporary Lodging: Child Welfare Collaboration

ODHS is working to reduce the number of children and young adults experiencing Temporary Lodging in hotels and similar settings due to lack of available, appropriate Child Welfare placements. There are strict limits on the use of Temporary Lodging including number of children and young adults, number of Temporary Lodging occasions, and number of nights per occasion. When children with intellectual and developmental disabilities are at risk for Temporary Lodging, collaboration between Child Welfare staff, Community Developmental Disability Programs (CDDP) and ODDS is essential to ensure all alternative avenues are exhausted, the use of Temporary Lodging is limited, and children are safe and supported.

3/16/2023Guide for CDDPs Assisting with Application for Medicaid for Child Referred for In-Home Services

Prior to being enrolled in In-Home Services, a child must be determined eligible for Medicaid. All applications for Medicaid must be processed in the OregONEligibility (ONE) system. This Worker Guide provides guidance to Community Developmental Disabilities Programs (CDDPs) who may be completing service eligibility and/or enrollment information in eXPRS and assisting families with application for Medicaid in ONE.

2/23/2023Professional Behavior Services

This guide supplements information available in applicable OAR chapter 411, divisions 304 (Professional Behavior Services) and 317 (Definitions) to assist service coordinators, personal agents, and behavior professionals in understanding, authorizing, invoicing, approving and/or monitoring professional behavior services.

2/20/2023PSW Differentials and Non-Standard Rates

​This guide describes the different PSW differentials that are available and the steps that the CME must take to ensure proper payment.

1/27/2023Eligibility Administrative Hearings, Process, and Testimony

​This Worker Guide provides guidance for the Oregon Department of Human Services (ODHS) Office of Developmental Disabilities Services (ODDS) Administrative Hearing procedures, policy, and guidance for eligibility hearings.

1/3/2023Exceptions to Individual Support Plan Hourly Cap for PSWs

​When a Service Coordinator or Personal Agent identifies a need to have a PSW work more than their assigned weekly limit for a specific individual, this Worker Guide will assist in understanding how to:
1. Establish criteria to determine the circumstances that must be present in order for a PSW to work more than their assigned weekly limit and receive payment from ODDS.
2. Outline the process and documentation requirements for approving exceptions to the PSW’s assigned weekly limit for situations that meet the established criteria.

1/1/2023Remote Employment and Day Support Activities (DSA) Services

The purpose of this worker’s guide is to outline information and requirements related to remote ODDS Employment and Day Support Activities (DSA) delivered by an agency. Remote services can be used to support a person to be more independent at work and in the community. They can be used to increase an individual’s self-management of tasks and job performance.

12/15/2022Admission Types and Discharge Processes from the Oregon State Hospital (OSH)

This worker guide explains the different admission types that individuals with Intellectual and Developmental Disabilities (I/DD) may access at the Oregon State Hospital (OSH) for care and treatment.

With different admission types come different discharge procedures. It’s important to understand the different responsibilities and processes to each admission type.

12/12/2022PSWs Exceeding Weekly Hour Limitations

​Case management entity roles and responsibilities in tracking, following up on, and taking action when PSWs exceed their weekly hour limitations.

10/1/2022Employment Services While Also Using SACU Services

​This worker’s guide outlines the process to access ODDS employment services while an individual also uses residential services with the Stabilization and Crisis Unit (SACU).

8/11/2022Attendant Care and Parents with I/DD

​The purpose of this Worker Guide is to provide Services Coordinators and Personal Agents more information on offering and authorizing in-home supports for people with Intellectual and/or Developmental Disabilities (I/DD) enrolled in services who are also parents of minor children.

7/1/2022Community Transportation (Non-Medical): Service Requirements

​This worker’s guide outlines requirements related to ODDS-funded Community Transportation services.

7/1/2022Long-Term Care Community Nursing (LTCCN) and Direct Nursing Services During Employment or DSA Services

​This worker’s guide outlines the process for requesting Long-Term Care Community Nursing (LTCCN) services or Direct Nursing Services (DNS) when a person eligible for ODDS services is:
- Working
- Using services in an employment service setting (funded through either ODDS or VR), or
- Using services in a DSA setting.

7/1/2022Rate and Dates - Timelines for Provider Agency Rate Changes

​This guide details the timelines for agency provider rate changes on or after July 1, 2022 when a new ONA assessment has been completed or an exceptional rate expires.

7/1/2022One to One “Solo” Employment Path Services

​The purpose of this worker’s guide is to outline information and requirements related to individualized (solo) 1:1 Employment Path Services. Employment Path includes services and supports to gain skills and experience that can be used in competitive integrated employment.

7/1/2022344-Day Billing Model: 24-Hour Residential Settings (Adults and Children) and Host Home Settings

​This worker guide provides an overview explanation of the 344-day billing model for 24-Hour Residential Program and Host Home Settings.

6/16/2022Individuals Releasing from Oregon Department of Corrections Facilities
To assist Case Managers in understanding the responsibilities and processes for releases from Oregon Department of Corrections (ODOC) to a residential community placement.
5/26/2022Project SEARCH

​Project SEARCH is a highly successful employment service model. The model is based on a business-led partnership with community agencies including DD provider agencies, DD case management entities, and Vocational Rehabilitation (VR). The goal is that interns leave the program with competitive integrated employment in the community.

5/5/2022ODDS Funding Review and Exceptions

​This guide explains ODDS exceptions policies and aids in the completion of the exception form.

3/14/2022Competitive Integrated Employment Requirements for Job Coaching

​This Worker’s Guide outlines job characteristics required to meet the definition of Competitive Integrated Employment.

3/14/2022Job Coaching Requirements

​This Worker’s Guide describes the requirements for ODDS Job Coaching services, including Initial, Ongoing, and Maintenance Job Coaching.

3/14/2022Job Coaching when a Person is Not Connected to VR

​The purpose of this Worker’s Guide is to outline requirements for ODDS-Funded Job Coaching when a person is not connected to Vocational Rehabilitation (VR) (i.e. not in plan with VR). This might happen, for example, when a person gets a job on their own, or during Employment Path or Discovery services.

3/14/2022Employment Services - Retention Payments

​This worker’s guide outlines circumstances under which ODDS may fund the job development 90-day job retention payment if a person obtains a job without using VR-funded services.

3/14/2022Job Stability with VR and Transfer to ODDS Job Coaching

​This Worker’s Guide outlines processes related to transfers from VR funded job coaching to ODDS funded job coaching, including when and how transfers take place.

3/14/2022Employment Services - Table of Contents

​Table of Contents for all ODDS Worker’s Guides for Employment Services.

3/3/2022Supported Self-Employment

​The purpose of this worker’s guide is to:
• Outline information and requirements related to ODDS services for supported self-employment.
• Outline information regarding the transition from VR to ODDS for supported self-employment services; and support a coordinated delivery of supported employment services available through Vocational Rehabilitation (VR) and the Office of Developmental Disabilities Services (ODDS).
• Ensure individuals with intellectual and developmental disabilities have support and opportunities to pursue self-employment on the same basis as individuals who do not have or experience a disability.

2/22/2022Enhanced/Exceptional Supports Status and Rates

When an individual is assessed to have certain extraordinary support needs, and a Personal Support Worker (PSW) is selected to deliver supports, the PSW may be eligible for a higher pay rate.  This guide describes the procedures for determining and authorizing Enhanced/Exceptional rates for PSWs.

12/23/2021Temporary Policy and Licensing Changes Addressing Staffing Crisis

​This worker guide describes short-term ODDS policy and licensing changes to maintain individual health and safety during this acute direct care and case management entity staffing crisis.

12/20/2021SACU Referral for Adult Residential Services

​This guide provides the process and expectations for adults with intellectual and developmental disabilities to be referred to the Office of Developmental Disabilities Services Stabilization and Crisis Unit (SACU) for residential services and placement.

9/1/2021Discovery Guidelines for Service Coordinators/ Personal Agents and Discovery Providers

​Overview: This guide provides the following information:
1. The Use of the ODDS Discovery Profile
2. Training Requirements
3. Discovery is Never Required
4. Who is Eligible for Discovery
5. Criteria for a SC/PA to Authorize the Service
6. Discovery’s Time Frame
7. Definitions and Purposes
8. Criteria for a SC or PA to Approve or Deny payment
9. Answers to Frequently Asked Questions

8/1/2021Direct Nursing Services - Medicaid Provider Enrollment

In order to assist potential providers, case management entities (CME’s) must be knowledgeable about the process and requirements for a nurse to become a qualified Medicaid provider of direct nursing services. Update: Effective August 1, 2021, a new category of provider called direct nursing services agency (DNSA) is eligible to provide direct nursing services (DNS).

7/30/2021Children's 24-Hr Residential - Temporary Transition Service Group Exceptions

​A temporary service group exception may be requested for a child entering 24-hour residential setting services for the first time from a family home or non-HCBS setting when it is determined that due to the child being in crisis and lack of behavior support plans or data, the child’s assigned Service Group results in a Payment Category that is not sufficient to meet the child’s intensive support needs during the transition into a residential service setting. 

7/19/2021Assistive Devices and Assistive Technology

​This guide:
• Applies to all assistive devices and assistive technology for individual and/or representatives receiving K-Plan services.
• Serves as the single point of direction about assistive devices and assistive technology for Services Coordinators and Personal Agents.

7/19/2021Home Modifications

​This guide applies to all home modifications for individual and/or representatives receiving services in in-home settings.

This guide serves as the single point of direction about Home Modifications for Services Coordinators and Personal Agents.

7/1/2021Community Transportation (Non-Medical): Local Match

​This Worker’s Guide outlines how individuals can access Medicaid local match transportation services, and how local governments (including CDDPs and brokerages) may participate in the program.

6/25/2021Employment Professional Qualifications and Training

This Worker Guide is intended to be the primary source of information regarding the training and credentialing requirements for Employment Professionals.

6/23/2021Personal Support Worker Employment Services Enrollment

​Personal Support Worker Enrollment and Qualification to Provide Employment Services to People with Intellectual or Developmental Disabilities (IDD).

6/18/2021Core Competency Training Requirements

​Employment Professionals are required to complete the 12 online Core Competency modules that are available in Workday Learning. This worker’s guide is designed to outline the training requirements and to provide quick access to the Core Competency modules.

6/9/2021Death Reporting

​This Worker’s Guide instructs Community Developmental Disabilities Programs/Support Service Brokerages and Children’s Intensive In-Home Services how and when to inform the Office of Developmental Disabilities Services of the death of a child or adult enrolled in its service.

5/17/2021Training Contingency Plan if Learning Management System Becomes Temporarily Unavailable

Many ODDS required trainings related to core competencies, credentialing and licensing are available on-demand in iLearn, the state’s current learning management system (LMS). Beginning June 16th, 2021, the state’s new LMS will be Workday Learning.

Occasionally the state’s LMS system may become unavailable due to a technical issue. If the LMS is scheduled to be offline for an extended period of time, ODDS will send out a communication about the LMS being offline and that the contingency plans listed in this Worker’s Guide will need to be implemented.

5/6/2021Guide for CDDPs Assisting with Application for Medicaid for Child Referred for Children’s Foster Care

Prior to being enrolled in Children’s Foster Care Services, a child must be determined eligible for Medicaid. Effective January 1, 2021, application for all Medicaid programs must be processed in the OregONEligibility (ONE) system. This Worker Guide provides guidance to Community Developmental Disabilities Programs (CDDPs) who may be completing service eligibility and/or enrollment information in eXPRS and assisting families with application for Medicaid in ONE.

4/22/2021ORS 427 Civil Commitments

​This worker guide explains ORS 427 Civil Commitments for individuals with intellectual disabilities, which may last up to 12 months and may be renewed annually as necessary.

4/7/2021Eligibility Determination Notice Guide

The Eligibility Determination Worker Guide provides instruction for completing decision notices on forms prescribed by the Department; the Notice of Determination (SDS 5103) is used for eligibility determinations, and Notification of Planned Action (NOPA) (SDS 0947) for denials and terminations of developmental disability services.

4/1/2021County-to-County Transfer Procedures

Individuals are enrolled via a SE48 CPA at the CDDP that operates in their County of origin. CDDPs must transfer eligibility if an individual’s county of origin changes (and a brokerage may have to transfer services to another brokerage). Individuals are immediately eligible to receive the same services in the new county of origin; OAR 411-320-0080 requires the new CDDP to initially accept the former CDDP’s I/DD eligibility determination.

3/26/2021Experiential Components of Discovery

​The new Discovery process includes specific experiential components, as well as career themes. This Worker’s Guide outlines these new processes, provides resources and gives updated guidance.

3/17/2021D&E Eligibility Consultation Worker Guide & Protocols

​This worker guide provides step-by-step directions for CDDP Eligibility Specialists (ES) to submit a case for consultation with the Office of Developmental Disabilities Services (ODDS) Diagnosis and Evaluation (D&E) Coordinator.

9/14/2020Attendant Care During an Inpatient Hospital Stay During the COVID-19 Pandemic

​Circumstances and procedures for concurrent attendant care and hospital admission during the time of the pandemic.

8/20/2020Supporting Individual Preferences in Medical Decision-Making

​Allowing individuals to make their choices known ahead of time helps to inform the people caring for them of their wishes and can help reduce anxiety and concern over medical treatment. The information in this document from ODDS is intended to support case managers to help guide families and caregivers in navigating difficult conversations about medical care, including end of life choices.

6/1/2020Hourly Stipend Payment for Required PSW Job Coach Training

​The 2019-2021 Collective Bargaining Agreement (CBA) between the Oregon Home Care Commission (OHCC) and Service Employees International Union (SEIU) was ratified on April 14, 2020. Under this agreement, Personal Support Workers who have obtained a Job Coach specialty are eligible to receive an hourly stipend for completing training required under OAR 411-345. Per the CBA, eligibility for this stipend will begin on April 14, 2020.

3/25/2020Benefits Counseling for Employment Path Services

​This worker’s guide outlines requirements related to Benefits Counseling delivered as part of ODDS Employment Path Community Services. This guide also includes:
I. Service Description and Requirements
II. Provider Training and Certification Requirements (Must be verified by a case manager before authorizing service)
III. Authorizing Benefits Counseling
IV. Approving Billing for Benefits Counseling
V. Additional Monitoring

1/17/2020Foster Care: 2:1 Staffing Authorization Procedure

​This worker guide has been revised to update the process for Community Developmental Disabilities Programs to request and receive authorization of a second caregiver (2:1) for children and adults in a Foster Care setting.

11/1/2019Personal Support Worker eXPRS Mobile-EVV Exceptions for Case Management Entities

​A new federal law requires states to implement an electronic way to verify the delivery of attendant care services, called Electronic Visit Verification (EVV). EVV is required for all Medicaid attendant care services that usually include an in‐home visit by a provider. For Oregon, this includes the following services and their OR procedure codes:
OR507 Daily Relief Care
OR526 Attendant Care, including ZE
OR502 State Plan Personal Care

11/1/2019Planning for employment services to maximize hours based on the person’s goals and with the standard of working at least 20 hours a week

​How Service Coordinators (SC) and Personal Agents (PA) assist individuals receiving or interested in receiving Supported Employment Services to achieve their goal for number of hours worked per week using the standard of 20 hours per week.

10/30/2019Statewide Release of Information

​Oregon has a new form that will allow state social service agencies to easily share information as needed and permitted by your clients. The statewide release of information, DHS form 3010 (titled Authorization for Sharing Individual Information), shall be used if a release is needed for agencies to coordinate and share information for the delivery of social services.

10/10/2019DD Eligibility and Enrollment (DDEE/0337) Worker Guide

​Accurate completion and submission of data into eXPRS is required for Medicaid authorized services and payments. This Worker Guide provides guidance for Case Management Entities (CME), such as CDDP and Brokerage staff who may be completing eligibility and/or enrollment into funded services through the DDEE (0337) in eXPRS.

10/2/2019Loss of Medicaid Eligibility

​Responsibilities of Service Coordinators (SC) and Personal Agents (PA) when individuals receiving services lose Oregon Supplemental Income Program Medical (OSIPM) or MAGI (OHP) eligibility.

7/26/2019Case Management Activities and the ONA

​This guide describes the impact of the Oregon Needs Assessment (ONA) on the delivery of case management services.

4/1/2019Statewide Employment First Referral and Release of Information

​This guide outlines information related to Oregon’s Statewide Employment First Referral (DHS form 4130) and the Statewide Authorization for Sharing Individual Information (Form 3010, commonly referred to as the Statewide Release of Information).

3/8/2019Employment Services for Transition-age Individuals and Youth while Special Education and Related Services Remain Available under IDEA

​This worker’s guide outlines the availability of ODDS employment services for Transition-age Individuals and Youth while Special Education and Related Services Remain Available under IDEA.

3/1/2019Administrative Examination Procedure Code Guide

​This Worker Guide provides instruction for ordering an Administrative Examination and use of Current Procedure Technology (CPT) billable codes. An Administrative Examination is an evaluation required by the Department of Human Services (DHS) used for eligibility determinations or case planning. A Report Authorization is a request for copies of existing records for a specified date range and is a prior authorization for Oregon Health Authority (OHA) Medicaid provider billing and payment.

2/1/2019Indirect Case Management Monitoring

​Indirect monitoring of services is the case manager’s use of documentation to ensure that the Individual Support Plan is effectively implemented and adequately addresses the needs of the person in services. This guide offers information about indirect monitoring.

1/1/2019State Plan Personal Care Services

​To provide guidance for a CDDP/Brokerage/CIIS case manager to implement SPPC services under the new ODDS personal care program rules Chapter 411 division 455.

8/1/2018Foster Care Support Needs Assessment Profile Exception Process Guidelines

​Exception amounts are specific for 2:1 caregiver support needs in each assessment section of the foster care support needs assessment profile. These guidelines are used to determine the 2:1 caregivers’ funding that may be approved. Hourly 2:1 rates can be found in the ODDS Expenditure Guidelines.

7/2/2018eXPRS Intake and Eligibility Procedures

​The purpose of this policy is to describe the process CDDPs use to add intake and eligibility details to eXPRS. It also updates the way in which individuals are terminated from the eXPRS system. The View Client Screen will include a link to an Eligibility Summary Page where the CDDP will enter intake and eligibility data.

7/1/2018Case Management Contact Requirements Technical Guide

​The Case Management Contact Requirements Technical Guide is designed to outline the Case Management Contact requirements for individuals with an Individual Support Plan (ISP) and provide technical assistance regarding implementation of this requirement.

6/22/2018Employment Training and Conference CE Approval

​To maintain a high quality of continuing education opportunities, ODDS has adopted a pre-approval process for continuing education programs and activities. Organizations that sponsor continuing education and training are required to seek pre-approval of their programs/activities, which signifies to all certified individuals that the programs/activities are appropriate to use toward meeting the requirements of their certification renewal program.

12/8/2017CIIS PSW Transition Rates

​Personal Support Workers (PSWs) who are working with children transitioning from CIIS program to adult services have reached a collective bargaining agreement with DHS to maintain their rate for the individual’s 18th year.

9/1/2017Career Development Planning & Decision Not to Explore Employment Implementation Guide

​This guide provides:
1. Information on how and when to complete the CDP and the DNE.
2. Outlines the required components of the CDP and DNE.
3. Instruction on how to submit the DNE to ODDS.

9/1/2017Career Development Planning: Who is Required to Have a Career Development Plan or Decision Not to Explore Employment

​This guide provides the following information:
1) Who is required to have a Career Development Plan (CDP) or Decision Not to Explore Employment (DNE)
2) Resources for Career Development Planning
3) Frequently Asked Questions (FAQs)

11/10/2016Direct Nursing MMIS Authorization and Payment Procedures

​In order to comply with federal and state requirements the department must assure an authorization and payment process for local Case Management Entities. Under OAR 411-380, DNS providers are issued Prior Authorizations and payments through the Medicaid Management Information System (MMIS).

9/30/2016Terminating Case Management Services

​Responsibilities of a Service Coordinator and Personal Agent when an individual enrolled in Case Management is exited from Case Management (CM) services and Developmental Disabilities Services are terminated.

9/30/2016Funding Review Request Denials by ODDS

​When either an individual or a case manager submits or request for a funding review request, under most circumstances, the Department will either approve the request or issue a Notification of Planned Action. In the event that the Department does not approve or deny the request, the Department request more information or determine that a funding review request is not needed when the requested service or items can be approved by the case management entity.

9/30/2016Rescinding a Notification of Planned Action

​A NOPA is sent to an individual receiving DD funded services when a decision to deny, reduce, suspend or terminate services has been made. If circumstances change following the issuance of a reduction or termination NOPA, there may be reasons to rescind the NOPA.

9/1/2016Service Agreement Form Manual

​The Provider Service Agreement Form (Service Agreement) (DHS4606) is a tool designed to assist the person directing the ISP, an employer, a provider, and the Case Manager with getting services to individuals who need them. It is a component of the ISP, and offers a way for a provider to acknowledge their acceptance of their part of the ISP while giving the individual the ability to control the personal information that is contained in the rest ISP.

8/12/2016Independent Provider Terminations and Inactivations

​Procedures for making a recommendation to inactivate or terminate an Independent Provider.

8/5/2016Fairview Training Center and Eastern Oregon Training Center Family Reconnection Procedures

​This worker guide articulates specific case management tasks to be completed when a family member of an individual who was discharged from either the Fairview Training Center (herein referred to as Fairview) or the Eastern Oregon Training Center (herein referred to as EOTC) desires to reconnect with said individual.

7/8/2016Personal Support Worker Progress Notes

​Personal Support Workers are responsible for providing progress notes outlining the tasks they performed with the individual served. This worker guide outlines the responsibility of the Services Coordinators, Personal Agents, and Administrative Staff in reviewing progress notes.

7/7/2016Expectations of Providers of Service Elements 50, 51 and 142 to Report Absences

​This guide clarifies the standards and practices for providers of Service Elements 50, 51 and 142 to report overnight absences in accordance with the Standards and Procedures.

2/1/2016Initial ISP Start and End Dates

​This Worker Guide describes the correct authorization period for an initial ISP.

2/1/2016Annual ISP Start and End Dates

​This Worker Guide describes the authorization period for an annual ISP.

2/1/2016Mid-Year ISP Changes

​This Worker Guide describes the procedures for making changes to services, service settings, resources, and/or providers in an existing ISP.

7/22/2015Personal Support Worker (PSW) Timesheet Requirements for Billing in Plan of Care

​PSWs are required to fully and correctly complete a timesheet and submit it to the CDDP/Brokerage prior to receiving payment. This Worker Guide details:
· Fully completed timesheet requirements and options
· Entering PSW timesheet data into eXPRS
· Required actions for Service Deliveries entered in error
· Options for Service Delivery review settings in eXPRS Plan of Care

11/14/2014In-Home Support for Children Under Age 18 and Residing in a Child Welfare-Funded Foster Home

​When considering placements for a child in the legal custody of CW who may be eligible for I/DD services, it is the procedure of CW to collaborate with the CDDP and explore placements in the following order of priority – Option 1 being the least restrictive setting:
1. CW-certified relative caregiver or foster home: CW-paid placement, child receiving in-home services through K-Plan and/or Waiver.
2. ODDS-certified foster home: CW-paid placement, child receiving in-home services through K-Plan and/or Waiver.
3. ODDS or CW certified foster home: ODDS-paid foster care placement.
4. ODDS residential placement.

11/14/2014Transferring from a Child Welfare-Funded Foster Care Placement to an ODDS-Funded Foster Care Placement

​In all cases where a child in the legal custody of Child Welfare (CW) is determined eligible for Intellectual/Developmental Disability (I/DD) services while in a CW-funded foster care placement, the CW worker and Community Developmental Disability Program (CDDP) Services Coordinator (SC) must work together to determine the least restrictive placement that is in the best interest of the child.

10/10/2014Waiver Service Requirements

​The Waiver Service Requirements Technical guide is designed to outline waiver service requirements and provide technical assistance regarding required followup in the event that service requirements are not met.

8/15/2014Process for Determining Service Rates for ALF and RCF Settings Through DD Funding

​Outlines the process for determining service rates and authorized funding for eligible individuals selecting ALF (Assisted Living Facility) or RCF (Residential Care Facility) setting to receive Community First Choice (K plan) state plan services funded through ODDS.

Environmental Safety Modification

​The purpose of this worker guide is to review the policies regarding the identification of and eligibility for Environmental Safety Modifications.

Modifications Implementation

​The purpose of this worker guide is to review the process for approving Environmental Modifications under K-Plan and Environmental Safety Modifications under the waiver, herein referred to collectively as modification or modifications.

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