The Illinois Department of Human Services (IDHS) Division of Developmental Disabilities (DDD) wanted to provide some initial guidance regarding the implementation of the Direct Support Professional (DSP), Intermediate Care Facility (ICF) Aide and other frontline staff wage increases. The formal (and full) guidance will not be released until closer to the effective date and pending the federal Centers for Medicare and Medicaid Services (CMS) approval.
Pursuant to Public Act 102-0699, the reimbursement rates for DSP and ICF Aide wages will increase by $1.00 per hour effective January 1, 2023, subject to approval by the federal CMS. This $1.00 per hour wage increase is for DSPs, ICF Aides and all other frontline personnel not subject to the Bureau of Labor Statistics (BLS) average wage increases, who work in residential (CILA, ICF) and community day services settings.
Similar to what was required for last year's wage increase, for the $1.00, at least $0.50 of the funds must be provided as a direct increase to base wages. The remaining $0.50 may be used flexibly for base wage increases for DSPs, ICF Aides and other frontline staff (not subject to the BLS increases).
As it relates to the above language that comes directly from Public Act 102-0699, please be aware: (1) "base wages" refers to the current wage you are paying each DSP or ICF Aide across your organization; and (2) the phrase "flexibly for base wage increases" refers to other options for providing increases, examples include wage increases targeted to specific DSPs or ICF Aides based on longevity, new employees, certain CILAs or ICFs, etc.
In an effort to help providers recruit and retain staff during this unprecedented staffing crisis, the DDD wanted to confirm that any DSP or ICF Aide wage increases provided between July 1, 2022, and December 31, 2022, will count towards the $1.00 per hour wage increase effective January 1, 2023 (subject to CMS approval) so long as the increase follows the above language that came directly from Public Act 102-0699. For example, if an agency implements a $0.50 per hour increase to all DSP wages across their agency effective October 1, 2022, they would not be required to do a second $0.50 per hour wage increase January 1, 2023, though they would be required to implement the other $0.50 per hour increase flexibly to wages for DSP and other frontline staff.
Another wage and rate adjustment coming in January 2023, also subject to federal CMS approval, is the implementation of a fifteen (15) percent Regionalization Factor for CILAs in Chicago, suburban Cook County, and the collar counties (list provided below). While the DDD is not prescribing how the Regionalization Factor is to be implemented, we are strongly encouraging all providers receiving the Regionalization Factor to utilize the additional funding towards direct care staff wages.
The Regionalization Factor will not impact an agency operating wholly outside of Chicago, suburban Cook, and the collar counties (Lake, McHenry, Kane, DuPage, and Will). For any agency operating CILAs both within and outside the Chicago, suburban Cook County, and collar counties region, the 15% Regionalization Factor will only be received on the Chicago, suburban Cook County, and collar counties part of that agency's operations. As such, it will be up to each agency based on the percentage of their operations that qualify for the Regionalization Factor to determine the implementation of the additional revenue for staff wages or other operational needs. These are issues that affected agencies will have to consider, evaluate, and make determinations on to ensure the continuation of quality services and supports within their organization moving forward.
Should you have any questions about implementation, please do not hesitate to reach out to the DDD at DHS.DDDComments@illinois.gov.
Thank you for all you do to serve and support individuals with I/DD.