1020 K.3.b. (services provided to avoid institutionalization)

Recommendation

Remove the following language from the first sentence: “in order to avoid institutionalization of the individual.”

Rationale

All waiver services meet this standard – if it is not needed, it should not be provided. All waiver services are provided to prevent institutionalization.

1020 K.4. (respite authorization in six month increments)

Recommendation

Maintain the current policy of allowing people to use respite hours when needed throughout the year. Remove the proposed language that would only allow individuals to use 240 hours of respite every six months.

Rationale

Presently, many people only use respite when needed resulting in a bank of hours that can be used, if needed, for emergencies or other unforeseen circumstances. If hours will be lost after the first six months of every State fiscal year, people will be encouraged, by this new policy, to use the hours before the end of the six months rather than bank the hours for possible later needs. If those needs do not materialize close to the end of the respite year, the hours may not be used. This would result in a cost savings to the Commonwealth which would be negated by the proposed regulation.

1020 K.5. (respite standards)

Recommendation

Remove this item.

Rationale

This subsection covers both agency and consumer-directed respite services. If the statement remains, an additional sentence should be added to clarify that agency directed respite services shall meet the same standards as consumer-directed respite.