Intermittent CILA (ICILA) Services and Supports Clarification of Program Scope and Billing - REVISED

Department of Human Services

Division of Developmental Disabilities

Information Bulletin

DD.22.002

Purpose:

This Information Bulletin informs Division of Developmental Disabilities (DDD) providers on approved services and billing under the Intermittent CILA (ICILA) program, effective January 1, 2022.

Program Scope:

ICILA services may be appropriate for waiver funded individuals who express interest in non-institutional, independent living options and who have a current Personal Plan which documents that the individual does not require continuous staff supervision (24/7 supports). Residential options within ICILA include living in one's own home, in a family member or relative's home or in an agency-controlled home that is not a 24-hour CILA.

ICILA services and supports may occur across a variety of settings (in and out of the home) and should enhance individual skill development and retention, leading to increased independence, integration and inclusion.

Note: Room and Board is not included in the rate for ICILA effective 1/1/22.

ICILA Awards:

The term "ICILA award" refers to the number of authorized weekly support hours for which an individual may receive billable services and supports under the ICILA program (ICILA bill codes 61H, 62H and 63H). As is outlined in a previous Information Bulletin (Clarification of DSP hours for Family and Intermittent CILAs), individual ICILA awards will be approved based on identified need. Requests for changes to the ICILA award must be directed to the appropriate Independent Service Coordination Agency representative.

Individuals in ICILA receive an average of 15 hours of support on a weekly basis under 61H, 62H or 63H. Their needs may require more or less support. The Division will consider an additional 5 hours for ICILA bill codes if the provider can demonstrate the individual requires additional support. If the individual requires more than 20 hours of support on a weekly basis, any hours above 20 will be reimbursed at the individual 1:1 rate (53R). The process for requesting additional staff supports (53R) is outlined in a previous Information Bulletin (Additional Staffing Requests/Awards under CILA & DT Programs).

ICILA Bill Codes:   

61H: 1:1 ICILA Services and Supports

62H: 1:2 ICILA Services and Supports

63H: 1:3 ICILA Services and Supports 

ICILA Staff:

Provider agency staff must be available for both scheduled and unscheduled in-person supports and services as needed by the individual(s) served and as specified in each individual's Personal Plan.

When provider agency staff are not in person, supervision or support shall be available by means of a provider managed 24-hour on-call system or an approved Remote Support provider.

ICILA Supports and Services:

ICILA includes an array of approved supports and services which enable individuals to maintain independent living. This array may include, but is not limited to:

  • case management
  • adaptive skill development
  • assistance with activities of daily living
  • community inclusion / integration
  • adult educational supports
  • social and leisure skill development appropriate to his/her needs
  • personal care, oversight and supervision
  • reduction of maladaptive behaviors through positive behavioral supports and other methods
  • nursing assessment and monitoring
  • non-medical transportation between the residence and other community locations
  • transportation training
  • assistance with financial management (banking, budgeting)
  • grocery shopping

Note: There is no Room and Board rate component included in the rate. Individuals would be responsible for rent, utilities and other costs traditionally covered under Room and Board. Providers that provide the residential setting to an individual may collect rent from the individual's earned and unearned income.

Rent Collection:

RENT is defined as the individual's regular payment to an owner or manager for the use of a residential site.

BOARD: Food supplies and non-food consumable supplies. Under no circumstance will a provider be able to collect for board.

Residential Site is Controlled by the Individual:

  • If the residential site is controlled by the individual, rent will be determined between the individual served and the landlord.

Residential Site is Controlled by the CILA agency:

  • If the residential site is controlled by the CILA agency, then Rent may be calculated, charged, and collected from the individual's unearned and/or earned income.
  • Rent shall not exceed the individual served portion of the HUD Fair Market Rents (FMR) plus a 20% modifier for the county the CILA site is located divided by the total of all full and part-time people residing in the home. (HUD/FMR Table for Illinois Counties) The HUD FMR rates in this table are estimates of 40th percentile gross rents for standard quality units within a metropolitan area or nonmetropolitan county. The provider agency or HF provider is allowed to add a 20% modifier to the rates listed in this table when determining the rent amount.
    • Rent Example: If there are three (3) individuals residing in a two (2) bedroom apartment and the HUD FMR rate (plus 20% modifier) for a two (2) bedroom home is $750 a month, the rent for the individual served may not exceed $250 a month.
  • Under no circumstances may the individual's responsibility for Rent in a provider-controlled site exceed the individual's unearned income minus a minimum $60.00 per month for the Personal Needs Allowance (PNA). For example, effective January 1, 2022 the Unearned Income eligible individual amount would calculate to $781.00 ($841.00 - $60.00 = $781.00).
  • An individual who does not receive or receives a reduced unearned SSA benefit because of Earned Income may have their applicable portion of Earned Income taken into consideration for payment of Rent up to the eligible individual amount for SSA benefits as determined by the SSA minus the individual's PNA.
    • Unearned Income Example #1: An individual has monthly Earned Income of $2,000 per month and is not eligible for any Unearned Income. The maximum amount of Earned Income which may be taken into consideration for payment of Rent but may not exceed the current SSA minus the individual's PNA.
    • Unearned Income Example #2: An individual has monthly Earned Income of $750 per month and is only eligible for Unearned Income of $420.00 (50% of the SSA amount). The maximum amount of Earned Income + Unearned Income which may be taken into consideration for payment of Rent may not be more than the current SSA minus the individual's PNA. The individual will retain $389.00 of their earned and unearned income (For example, $750 Earned + $420 Unearned - $781.00 (PNA offset included) = $389)

Note: While $781 per month is the (CURRENT MAXIMUM) allowable Rent amount, it may be less than that amount based on the HUD FMR calculation.

ICILA Billable Time:

ICILA bill code services and supports are billable in 15-minute increments and include direct contact (person-facing, virtual or phone) and indirect contact (non-person facing) between provider agency staff and the individual(s) served as outlined below.

The ICILA rate methodology includes a staff productivity factor, meaning the relationship of billable vs. non-billable activities. Using this methodology, the ICILA model allows for billing of the direct contact services that support an individual and the built-in productivity factor ensures that there is compensation for many activities associated with, but are not a direct contact service to, the individual (such as driving time to and from meeting with the individual served). The Division has allowed additional, but limited, indirect contact time as billable.

Documenting ICILA Bill Code Direct Contact Time

  • Direct contact time is direct engagement with the individual(s) in-person, by phone or virtually.
  • Reimbursement rate is set according to the ratio of the number of individuals served at one time by one provider agency staff (1:1, 1:2, 1:3). Therefore, agency staff must document the date of service, start time, stop time, and names of individuals served.

Documenting ICILA Bill Code Indirect Contact Time

  • While the predominance of billing for any day, week or month must be direct contact, billing may also be submitted for indirect services and supports.
  • Billing for indirect services and supports may not exceed 15% of the weekly award.
    • If an individual is awarded 10 hours per week, no more than 1.5 of those hours may be billed as indirect support.
    • If an individual is awarded 15 hours per week, no more than 2.25 of those hours may be billed as indirect support.
    • If an individual is awarded 20 hours, billing for indirect services is capped at 3 hours per week.
  • Indirect supports may include:
    • Documenting services of the in-person visits (case or progress notes)
    • Contact with family or guardian(s)
    • Contact with external behavioral or medical professionals
    • Contact with pharmacies for medication management
    • Contact with landlords, utility companies, household maintenance companies or other service providers that would support the person's living arrangement
    • Contact to maintain a person's benefits or entitlements
    • Contact with law enforcement / crisis abatement

Note: Indirect supports should never be billed at a 1:2 or 1:3 rate.

* Agency staff must document the date of service, start time, stop time, and name of individual served.

The services and supports noted above may also be conducted directly / in person. Documentation of services must clearly indicate whether the services and supports were Direct or Indirect.

Documenting 1:1 DSP (53R) Contact Time

  • Contact time is direct in-person engagement with the individual.
  • Note: there is no group or indirect contact time billable to 53R.

Billing

ICILA (61H, 62H, 63H)

  • Billing for ICILA bill code services and supports (61H, 62H and 63H), both direct and indirect, may be submitted for all hours of service up to the individual's award limit, per day and per month, and considering the limitations on indirect contact.
  • Daily limit: 10 hours
  • Monthly limit: 90 hours
  • Providers SHOULD NOT front load billing. Providers should limit ICILA billing to those hours allocated each week/month.
    • Example 1: An individual has 10 hours of ICILA per week. They receive 1.5 hours of indirect support (Staff support for calls about their lease, case notes), 7 hours of 61H (Staff support of 2.5 hours for an doctor's appointment, 45 minutes help learn new cooking skills, 45 minutes for errands and 3 hours for lunch and a movie) and 1.5 hours of 62H (staff support to go to the grocery store with their roommate).
    • Example 2: An individual has 20 hours of ICILA per week and 10 hours of 53R. They receive 3 hours of indirect support (Staff support for case notes, calls to family and doctor's office calls to address new diagnosis), 17 hours of 61H (all directed at shorter periods that provide personal care and support each morning) and 10 hours of 53R (also directed at personal care and support in the evening).

1:1 Hours (53R)

  • Billing for 1:1 DSP (53R) support may be submitted for all hours of service up to the individual's award limit.
  • No daily or monthly limit.
  • Providers should not front load billing, meaning, providers should not bill all ICILA support hours first during the month and then end the month with 1:1 hours.

Notes:

  • 61H, 62H, 63H and 53R for supports should not occur for services or supports which are provided at the same time under other billing codes such as Behavior Intervention and Treatment, Counseling, Community Day Services or the Supported Employment Program.
  • Providers SHOULD NOT front load billing during the service year. ICILA Hours are limited on a daily and monthly basis.

Providers must maintain, and be able to produce, documentation of all services and supports. The Division may audit the documentation to verify billing.

Effective Date:

1/1/2022