Chapter 2

Participating Provider

Page 5, 3rd bullet

With current staffing challenges, providers are unable to guarantee staffing will be available within 30 days when referral is accepted. A provider should be able to accept a referral to begin the process without having to guarantee staffing. The provider may assess a higher level of skill is necessary to provide the support and then have to hire for a position necessary to meet the individuals assessed need. This is especially the case for individuals with higher level of needs.

Page 8, 2^nd bullet

DSP requirements throughout the manual, regulation and available in guidance should all match. Regulation requires two observations of DSPs annually.

Page 10, 1^st bullet

Often hospitals request support or assistance from the in-home provider to help with the individual’s acceptance of services while in the hospital (i.e. medication administration, support with hygiene). If the hospital is requesting support, the provider should be able to bill for the services provided.

Provider Qualifications

Page 12

The requirement for a provider to inform the individual of his/her responsibility to have a backup plan does not match regulatory requirements.

Page 21

Core Competency Requirements should be consistent whether you are reading guidance, regulations or this manual so that providers can easily meet requirements.

Specific Settings and Protections

Page 30, 1^st bullet under Intent

Using quotes in the following sentence communicates a tone of condescension toward individuals with developmental disabilities.

Individuals are supported in life-informed “real” choices and autonomy.

Chapter 4

Individual Planning Calendar

• Strike ‘supports package’ language as this language is no longer applicable.

Assistive Technology

• Service Definition-

• Remove language that defines AT as portable.

• Service exclusion –
  • AT equipment covered should be what the approved professional has assessed to be necessary after completing the person centered assessment process.
  • Where is the listing of items and their specific time-limited usefulness found? Excluding this information to include where the usefulness listing will be sourced from allows for inconsistent interpretation of this section.
  • Certain equipment should be reasonably allowed based on diagnosis. The time and financial resources spent to obtain a communication device for someone who has a communication barrier diagnosis documented is time that can be spent providing quality services.
• Excluding the cost of shipping, freight and delivery associated with AT delivery is not reasonable as those are costs incurred in order to receive the AT item. A provider does not supply products at cost. These additional charges are typical of any type of purchase and necessary and should be included in allowable costs when pursuing an AT item.
• Echo the comments submitted by M. McWhirt.

Community Guide

• Service Definition/Description
  • The General Community Guide and the Community Housing Guide services should have separate sections that outline ‘Service Definition/Description’. They are separate and distinct services.
• Service Limitations
  • The paperwork itself required to support the allowable activities under the Community Guide Housing service will exceed the 25% allotted time allowed to be conducted without the individual.
  • Adequate documentation that service is unavailable through other means is the support coordinator’s burden to bear and this should be specified. This section simply states ‘the provider’.

Electronic Home-Based Supports

• Service Definition
  • Use of EHBS is not limited to the home setting and must include use in the community.
• Service Units and Service Limitations
  • There are no service units specified for the ongoing use, to include training, and a unit should be defined and included. EHBS includes both items and services.

• Remove the unnecessary limitation of ‘Receipt of EHBS service may not be tied to the receipt of any other covered waiver or Medicaid service’.
• Service Documentation Requirements
• Recommend removing “Provider” from the title and specifying who is responsible for completing the activity and the documentation of that activity.

Transition Services

• Service Limitations and Service Units
  • Remove the limitation that $5,000 is available once in a lifetime. Recommend something that allows for the flexibility to access funds again if the individual meets the service definition criteria a second time during their lifetime.

In-home

• Criteria/Allowable Activities
• Safety supports may also be needed by the individual during the provision of ADLs and IADLs, when supporting the individual with replacing challenging behaviors, while providing supports with transportation and during the provision of general supports and should be documented as an allowable activities throughout each bulleted description.
• Service Limitations –
• This manual and regulation uses the language ‘natural supports’ when describing back up plans. This language must be acceptable when that same language is used by the provider. Service authorizations are currently being pending and the justification is that ‘more details are needed’.

• Semi-Predictable Events
  • Community Engagement and In-Home Services are alike in that the providers of both services cannot foresee events such as inclement weather which may be required services to be canceled and both services should allow for the flexibility to accommodate individual choice and preference and/or inclement weather.
  • The semi-predictable events section for in-home should mirror the semi-predictable events section for the Community Engagement (Chapter 4, Page 105) as both services are similar in that events are not always predictable. However, the option to add hours proactively to a community engagement authorization is allowable but not an in-home authorization. (Chapter 4, Page 160).

Shared Living Supports

• Reimbursement for allowable expenses
  • Basing a methodology for calculating allowable expense for food reimbursement off of a USDA Low-Cost Plan from June 2015 is not acceptable. The cost of food fluctuates as we are currently seeing and a reimbursement formula that takes into account those fluctuations should be the standard.