If authorized waiver services cannot be delivered because no staff is available to provide them, the provider **cannot bill** for services that were not actually provided. Medicaid requires that billing reflect services actually delivered.

What providers should do when a DSP is on vacation and no substitute is available:
1. **Do not bill** for days services were not provided — this is a compliance requirement, not optional.
2. **Document the service gap**: Note in the client record why services were not provided and what steps were taken to find coverage.
3. **Notify the support coordinator/case manager**: Service gaps should be reported to the client’s Medicaid support coordinator, who may be able to assist with arranging alternative supports.
4. **Review for pattern issues**: Recurring unbillable gaps due to staffing should trigger a staffing plan review and, if necessary, discussion at the next ISP meeting about backup support options.
5. **Do not document services that did not occur** — falsifying service documentation is Medicaid fraud.

This situation underscores the importance of maintaining a PRN pool or staffing agency relationship to prevent service gaps.