The Centers for Medicare & Medicaid (CMS) Final HCBS Rule requires that all states ensure HCBS Provider Settings are compliant with the Final HCBS Rule prior to March 17, 2023. HCBS Providers may access the Final Rule by way of The Electronic Code of Federal Regulations Website.
To streamline and collect HCBS Provider reporting, Illinois has developed a Site Validation Tool to be used for each agency site, as well as a virtual platform (HFS Sharepoint's Settings Compliance Validation Portal) to collect submissions.
Provider Agency Level Submissions - Organizational Policies
- The Provider must submit requested organizational policies to the Portal within 60 days of the receipt of this notification.
Provider Site Level Submissions - Site Evidence
- Providers must submit evidence of compliance for each site where HCBS services are provided using the Site Validation Tool.
- Providers should submit evidence for 1-20 sites by April 20.
- Providers should submit evidence for the 21st - 50th site by May 18.
- Providers with more than 50 sites should submit the remaining sites above 50 by June 15.
- These timeframes have been established to ensure there is adequate time for validation and implementation of any needed compliance action plans by March 17, 2023
Compliance Reviews
- The Division of Developmental Disabilities will review and develop Compliance Action Plans with Providers that submit evidence that lacks sufficient compliance with the Final Rule.
- A Provider that is unable to come in compliance with the plan by March 17, 2023 will be unable to serve HCBS participants after March 17, 2023.
For questions regarding the tool or to request guidance on remediation strategies, IDHS-DDD Providers may outreach DHS.HCBS@illinois.gov.
ILLINOIS HCBS SITE VALIDATION POLICY AND IMPLEMENTATION EVIDENCE COLLECTION
IDHS-DDD Providers must submit organizational policies and site specific evidence through the HFS Sharepoint's Settings Compliance Validation Portal.
Questions and concerns may be submitted to DHS.HCBS@illinois.gov.
- HCBS Settings Expectations are listed in the left-hand column. Examples of Supportive Evidence are provided in the right-hand column. Unless the "Sources of Evidence of Compliance with Setting Rule" column notes otherwise, providers MUST submit examples of evidence to support that the provider is following the Expectation and provide as much policy documentation as possible to support that the agency's sites are in compliance with the federal Settings Rule. The lists of evidence options are not exhaustive. Feel free to provide additional or alternative information to support the site's position. It is the provider's responsibility to submit as much evidence as possible to show the waiver-operating agency that the provider is compliant with each HCBS settings expectation.
- DDD provider agencies are also required to submit organizational policies through the portal that reflect the expectations. Select the agency name and administrative office and upload the policies. Please note, a provider only needs to upload these policies once for the agency if the policies apply to all provider-controlled/owned sites.
- Each piece of evidence should be named to indicate which HCBS Settings Expectation they support. For example, file names for photographs of participant engagement in the community and/or receipts related to community engagement should include "1b." Providers may submit the same piece of evidence for more than one Settings Expectation. For example, a single source of evidence may reflect that participants have been educated on their right to freedom from coercion (3c) and their right to freedom from restraint (3d). We suggest including "3c.3d" in the file name.
- Providers may submit examples of evidence that are not already listed in the right-hand column of the tool if they support an HCBS Settings Expectation. Please name the evidence to reflect which HCBS Settings Expectation it supports.
- Due to the pandemic, sites can provide evidence from 2019 prior to the pandemic if that best shows implementation of the settings rules components.
- If necessary, work with the appropriate ISC and/or CDS provider to gather implementation evidence.
- The State recommends that all sources of evidences be submitted at one time. Please upload a zip folder that contains all sources of evidence. A video tutorial on file submission is available.
- Providers will receive a confirmation e-mail after submitting evidence. IDHS-DDD staff will outreach providers with additional guidance once they begin their review process.
SPECIAL NOTE: It is the site's responsibility to provide sufficient evidence to clearly prove that it is in compliance with the Settings Rule. If the desk auditor cannot determine compliance from the evidence submitted, the site will be recommended for an on-site review, a compliance action plan or both. Therefore, it is incumbent upon the site to be as thorough as possible in gathering evidence to support its compliance.
ORGANIZATIONAL POLICIES SUBMISSION
Please select your provider name and administrative office to submit policy documentation.
**NEW: We are asking only for the policies that reflect the settings expectations. The other items below are optional.
**NEW: Day services must submit policy evident for #11 as well.
Expectation |
Sources of Evidence of Compliance with Settings Rule
(This list is not exhaustive. Feel free to provide additional or alternative information to support the site's position.)
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The setting is integrated in and supports full access of individuals receiving Medicaid HCBS to the greater community, including:
1a) Opportunities to seek employment and work in competitive integrated settings
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PROVIDER DOES NOT HAVE TO COMPLETE. DDD IS RESPONSIBLE FOR THIS EXPECTATION. |
1b) Engage in Community Life |
Policy Documentation:
- Description of process or actions by staff to support, monitor, improve, and enhance individual integration in and with the broader community
- Policy allowing flexibility for staff, including permission for hours worked away from setting while supporting/training individual in the community
- Plans for program to match staff and individuals with like interests for joint activities in the community. (optional)
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1c) Control Personal Resources |
Policy Documentation:
- Policy regarding individual's rights to control personal resources
- Policy/training materials regarding helping individuals understand where their money is going, understanding their bank book, etc.
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1d) Receive services in the community, to the same degree of access as individuals not receiving Medicaid HCBS. |
Policy Documentation:
- Policy requiring staff training and knowledge on HCBS Settings requirements or staff training materials showing that staff (DSP and QIDPs) have been trained on HCBS Settings requirements. If submitting staff training materials, staff sign in sheets showing all staff in the setting have been trained must be included.
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2a) The setting is selected by the participant from among setting options including non-disability specific settings and an option for a private unit in a residential setting. |
PROVIDER DOES NOT HAVE TO COMPLETE. DDD IS RESPONSIBLE FOR THIS EXPECTATION. |
2b) Setting options are based on the individual's needs, preferences |
PROVIDER DOES NOT HAVE TO COMPLETE. DDD IS RESPONSIBLE FOR THIS EXPECTATION. |
3a) Ensures an individual's rights of privacy |
Policy Documentation:
- Policy on ensuring privacy while assisting with personal care
- Pages from staff training manual on HIPAA (optional)
- Description of how setting ensures privacy during individual care planning, medication passes, weigh-ins, etc. (optional)
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3b) Ensures an individual's rights of dignity and respect |
Policy Documentation:
- Policy ensuring the individual rights of dignity and respect
- Page(s) from staff training materials on how to communicate with individuals with disabilities (optional)
- For settings serving individuals with hearing impairments, sign in sheets for staff training in human interaction and communication in ASL. (optional)
- Copies of training for individuals receiving services on rights and self-advocacy. (NOTE: This is not a rights statement.) (optional)
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3c) Ensures an individual's right of freedom from coercion |
Policy Documentation:
- Policy outlining the organization's commitment to individual's right of freedom from coercion
- Documentation on training for individuals on what coercion is, as well as other forms of abuse and neglect. (optional)
- Sample of staff training material on individual rights (optional)
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3d) Ensures an individual's right of freedom from restraint |
Policy Documentation:
- Policy regarding individual consent to restraints/restrictive intervention
- Staff training materials or policy regarding alignment of individual's person-centered plan and accompanying implementation strategy with any individualized restraints or restrictive measures
- Policy that defines restraint and gives examples
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4a) The setting optimizes, but does not regiment, individual initiative, autonomy, and independence in making life choices, including but not limited to daily activities |
Policy Documentation:
- Policies that outline the organization's effort to support individual initiative, autonomy and independence in making life choices including but not limited to daily activities
- Sample of training materials on person-centered planning and implementation strategy development for both staff and individuals, including identification of individual preferences on scheduling and activities
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4b) Optimizes, but does not regiment individual autonomy, and independence in making life choices, including but not limited to physical environment |
Policy Documentation:
- Policy and training on individual's right to access typical facilities in a residential setting or common areas in a non-residential setting
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4c) Optimizes, but does not regiment individual autonomy, and independence in making life choices, including but not limited to with whom to interact |
Policy Documentation:
- Policy regarding individual choice on whom to interact with
- Policy on sex education.
- Training materials or policy on how to safely use the internet
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5) Facilitates individual choice regarding services and supports, and who provides them |
Policy Documentation:
- Policy requiring support for individuals to make "informed choices"
- Policy outlining that the organization will frequently check in with individuals to document if there are changes to their choices and preferences
- Description of how staff are trained and monitored on their understanding of the settings criteria and the role of person-centered planning and implementation strategy development. (optional)
- Copies of information distributed to individuals regarding their right to request meetings, change/add providers, or change/add services (optional)
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6a) Individuals have the freedom and support to control their own schedules and activities, |
Policy Documentation:
- Policy and/or staff training regarding individual freedom to set own schedule and activities
- Staff training material regarding meal accommodations based on individual preference and schedule
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6b) Individuals have access to food at any time |
Policy Documentation:
- Policy and staff training regarding individual right to access food at any time (unless rights restrictions documented) (example could include the ability to eat at a time of their choosing., training on courtesy and reasonableness around mealtimes and conflict-resolution as needed)
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7) Individuals are able to have visitors of their choosing at any time. |
Policy Documentation:
- Policy and staff training regarding individuals right to have visitors of their choosing at any time, without advance notice or special permission, consistent with the tenets of respect, courtesy and reasonableness
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8)The Setting is physically accessible to the individual |
Policy Document:
- Policy reflecting the provider's responsibility to monitor on an ongoing basis that an individual's accessibility needs are being met
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FOR RESIDENTIAL SITES ONLY (9-10)
Expectation |
Sources of Evidence of Compliance with Settings Rule
(This list is not exhaustive. Feel free to provide additional or alternative information to support the site's position.)
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9) The unit or dwelling is a specific physical place that can be owned, rented, or occupied under a legally enforceable agreement by the individual receiving services, and the individual has, at a minimum, the same responsibilities and protections from eviction that tenants have under the landlord/tenant law of the State, county, city, or other designated entity. For settings in which landlord tenant laws do not apply, the State must ensure that a lease, residency agreement or other form of written agreement will be in place for each HCBS participant, and that the document provides protections that address eviction processes and appeals comparable to those provided under the jurisdiction's landlord tenant law |
Policy Documentation:
- Policy and/or staff training regarding residency agreements and eviction appeal rights
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10a) Each individual has privacy in their sleeping or living unit |
Policy Documentation:
- Policy on ensuring privacy while assisting with personal care in individual sleeping or living unit
- Pages from staff training manual on HIPAA (optional)
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10b) Units have entrance doors lockable by the individual, with only APPROPRIATE staff having keys to door |
Policy Documentation:
- Policy on individual right to lockable doors
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10c) Individuals sharing units have a choice of roommates in that setting |
Policy Documentation:
- Policy and/or staff training regarding choice of roommates
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10d) Individuals have the freedom to furnish and decorate their sleeping or living units within the lease or agreement |
Policy Documentation:
- Policy reflecting individual's rights to express their individuality
- Policy around balancing preferences when individuals share bedrooms
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11) Any modification of the additional conditions, under §441.301(c)(4)(vi)(A) through (D), must be supported by a specific assessed need and justified in the person-centered service plan. The following requirements must be documented in the person-centered service plan
- Identify a specific and individualized assessed need.
- Document the positive interventions and supports used prior to any modifications to the person-centered service plan
- Document less intrusive methods of meeting the need that have been tried and did not work
- Include a clear description of the condition that is directly proportionate to the specific assessed need
- Include regular collection and review of data to measure the ongoing effectiveness of the modification
- Include established time limits for periodic reviews to determine if the modification is still necessary or can be terminated
- Include the informed consent of the individual
- Include an assurance that interventions and supports will cause no harm to the individual
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Policy Documentation:
11a-h) Policy and/or staff training materials on person-centered planning and implementation strategy development for modifications, including process for garnering approval of the Human Rights Committee.
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FOR BOTH CDS AND RESIDENTIAL (NEW)
Expectation |
Sources of Evidence of Compliance with Settings Rule
(This list is not exhaustive. Feel free to provide additional or alternative information to support the site's position.)
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11. Any modification of the additional conditions, under §441.301(c)(4)(vi)(A) through (D), must be supported by a specific assessed need and justified in the person-centered service plan. The following requirements must be documented in the person-centered service plan
- Identify a specific and individualized assessed need.
- Document the positive interventions and supports used prior to any modifications to the person-centered service plan
- Document less intrusive methods of meeting the need that have been tried and did not work
- Include a clear description of the condition that is directly proportionate to the specific assessed need
- Include regular collection and review of data to measure the ongoing effectiveness of the modification
- Include established time limits for periodic reviews to determine if the modification is still necessary or can be terminated
- Include the informed consent of the individual
- Include an assurance that interventions and supports will cause no harm to the individual
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Policy Documentation:
11a-h) Policy and staff training on person-centered planning and implementation strategy development for modifications, including process for garnering approval of the Human Rights Committee.
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IMPLEMENTATION EVIDENCE SUBMISSION
- For all sites, please submit the following evidence electronically through the HFS portal. IDHS staff will contact sites that require an onsite validation interview or if they have any additional questions.
- For each expectation listed in the left-hand column, provide as much implementation evidence as possible to support the site's position from the pre-screen that it is in compliance with the federal Settings Rule. The lists in the right column are not exhaustive. Feel free to provide additional or alternative information to support the site's position.
- Clearly label each implementation evidence to indicate which expectation it is supporting; eg. 1b or 5 or 4c. Evidence received that is not clearly labeled will be disregarded by the desk auditor and could result in the site being recommended for an on-site review, a compliance action plan or both.
- If necessary, work with the appropriate ISC or CDS provider to gather implementation evidence.
**NEW: Day services must submit site evident for #11 as well.
Expectation |
Sources of Evidence of Compliance with Settings Rule
(This list is not exhaustive. Feel free to provide additional or alternative information to support the site's position.)
|
The setting is integrated in and supports full access of individuals receiving Medicaid HCBS to the greater community, including:
1a) Opportunities to seek employment and work in competitive integrated settings
|
PROVIDER DOES NOT HAVE TO COMPLETE. DDD IS RESPONSIBLE FOR THIS EXPECTATION. |
1b) Engage in Community Life |
Implementation Evidence:
- Examples of staff schedules with a focus on individual's community access and participation as well as evidence that the activities occurred post-event or activity.
- Documentation showing that the setting does not solely or primarily rely on "reverse integration" or bringing the community in to the setting, e.g., copies of activity calendars or schedules, list of community activities offered
- Person-centered plans and implementation strategies that show personal schedules, any technology used to track individualized schedules, documentation of how individuals are getting where they need to go (e.g., public transportation), etc.
- Description of daily activities that reflect opportunities for engagement with the broader community, e.g., list of specific opportunities for community interaction
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1c) Control Personal Resources |
Implementation Evidence:
- Documentation of training provided to individuals on how to manage their personal resources
- Evidence of planning, money management and accounting of individuals' funds, such as bank books or bank account statement
- Picture and/or description of secure place to store personal belongings
- Evidence of staff training on individual rights as well as staff responsibilities associated with supporting management of personal resources
- Copies of person-centered planning documents and implementation strategies that outline supports needed associated with how individuals can access their money
- Evidence that individuals are able to keep their own money without having to ask staff for it.
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1d) Receive services in the community, to the same degree of access as individuals not receiving Medicaid HCBS. |
Implementation Evidence:
- Excerpts of individuals' person-centered plans and implementation strategies showing individuals' participation in the community
- Examples of trainings provided to individuals on how to access public transportation
- Examples of posted or distributed contact information and schedules for local transportation providers
- Examples of assistive technology used by individuals to increase independence in the community
- Descriptions of person-centered plans and implementation strategies that reflect interaction with the broader community
- If limited access due to rural/remote setting, information about level of integration experienced by neighbors not receiving HCBS supports for comparison
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2a) The setting is selected by the individual from among setting options including non-disability specific settings and an option for a private unit in a residential setting. |
PROVIDER DOES NOT HAVE TO COMPLETE. DDD IS RESPONSIBLE FOR THIS EXPECTATION. |
2b) Setting options are based on the individual's needs, preferences |
PROVIDER DOES NOT HAVE TO COMPLETE. DDD IS RESPONSIBLE FOR THIS EXPECTATION. |
3a) Ensures an individual's rights of privacy |
Implementation Evidence:
- Photos of locks on the door and/or private bedrooms
- Handbooks that are given to guardians and individuals receiving services on their right to privacy
- Description of how staff are trained and monitored on their understanding of an individual's rights of privacy
- Evidence of trainings and materials for individuals being served about their rights to privacy
- Evidence that the choice of a lock or key has been offered and the individual has declined the opportunity or has tried it and didn't care for it
- Evidence that a site is working with an individual to create opportunities for privacy
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3b) Ensures an individual's rights of dignity and respect |
Implementation Evidence:
- Evidence that individuals are informed of their rights of dignity and respect
- Examples of how an individual prefers to be addressed by staff is documented within their person-centered plan and implementation strategy
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3c) Ensures an individual's right of freedom from coercion |
Implementation Evidence:
- Examples of person-centered plans and implementation strategies that vary among individuals based on their individual preferences on scheduling of service provision and activities
- Evidence that visitors have been present at regular frequencies
- Examples of ways the setting employs to ensure ready access to information regarding filing an anonymous complaint. This could be through postings, handouts at annual meetings, folders of materials available to people in the home or CDS, etc.
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3d) Ensures an individual's right of freedom from restraint |
Implementation Evidence:
- Evidence the site assumes everyone is assured the right of freedom from restraint unless the use of restraints is present in an individual's behavioral support strategy
- Evidence regarding the role of the Human Rights Committee and data to evidence escalation of behavioral concerns leading to the need for the HRC
- Evidence of individual and/or representative have approved modification, documentation within the person-centered plan and implementation strategy
- Evidence of staff training on the need for and appropriate use of restraints
- Use of restraints report for past six months
- Summary of efforts and evidence of behavioral support strategies to reduce use of restraints that have been reviewed with and signed off on by the legal guardian.
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4a) The setting optimizes, but does not regiment, individual initiative, autonomy, and independence in making life choices, including but not limited to daily activities |
Implementation Evidence:
- Examples of person-centered plans and implementation strategies that vary among individuals based on their individual preferences on scheduling of service provision and activities
- Examples/calendars of a variety of individuals' schedules for either the home or the CDS that show that different activities were offered at the same time.
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4b) Optimizes, but does not regiment individual autonomy, and independence in making life choices, including but not limited to physical environment |
Implementation Evidence:
- Examples or pictures of assistive technology and environmental modifications that allow individuals to access common areas of the setting and/or enter and exit the setting
- Examples of person-centered plans and implementation strategies that support individual autonomy to enter/exit setting as they wish
- Evidence of individual and/or representative consent to modifications, documentation within the person-centered plan and implementation strategy of behavioral support plan.
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4c) Optimizes, but does not regiment individual autonomy, and independence in making life choices, including but not limited to with whom to interact |
Implementation Evidence:
- Evidence that visitors have been present at regular frequencies
- For CDS, evidence that the setting has procedures in place to accommodate visitors during the day.
- Examples of ways a site has worked with an individual to accommodate a visitor during the day.
- Evidence that individuals receiving supports and their families/guardians have received notice of right to receive visits
- Examples of person-centered plans/implementation strategies that support an individual's ability to independently enjoy life, with and without staff support
- Proof of sex education. If restricted, evidence the restriction went through the Human Rights Committee
- Evidence of training on internet safety and safe ways to use the internet to meet people and interact
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5) Facilitates individual choice regarding services and supports, and who provides them |
Implementation Evidence:
- Examples of person-centered Plans and implementation strategies that document individual requests for services and supports
- Evidence from past such requests that show how changes were made to accommodate individuals' requests
- Evidence that individuals participate in the hiring of DSPs, including participating in interviews and/or opportunities to meet new staff before they start
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6a) Individuals have the freedom and support to control their own schedules and activities, |
Implementation Evidence:
- Examples of person-centered plans and implementation strategies that address individual freedom and support to control their own schedules and activities
- Examples of activities individuals have engaged in with and without staff support
- Examples of varied meal choices and service scheduling among individuals within the setting
- Evidence that individuals have the freedom to set own schedule and activities. Examples of such.
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6b) Individuals have access to food at any time |
Implementation Evidence:
- Description of snacks available to individuals at all times
- Photos of food storage areas showing absence of locks, array of snacks, etc.
- Evidence that staff work to accommodate individuals preferences and schedules as it relates to eating.
- Description of how staff work in real time to adjust eating schedules to deal with changes in individuals' schedules or preferences
- If an individual with a rights restriction for access to food lives in the settings, evidence that all others in the home have full access to food at any time
- Examples of house agreements that show individuals give up this right as a matter of courtesy (I can't eat my housemate's food, for example)
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7) Individuals are able to have visitors of their choosing at any time. |
Implementation Evidence:
- Evidence that individuals are informed of their right to visitors at any time
- Documentation regarding visitor frequency
- Examples of person-centered plans and implementation strategies that document individual consent to any visitor restrictions
- Examples of resident agreement/inter-roommate agreements detailing how individuals agree to handle visitors
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8)The Setting is physically accessible to the individual |
Implementation Evidence:
- Pictures evidencing that the setting is physically accessible to individuals.
- Examples or pictures of assistive technology and environmental modifications that allow individuals to access common areas of the setting; and/or enter and exit the setting
- List of individuals receiving supports at the site who have vision, hearing or physical limitations
- Copies of person-centered plans and implementation strategies documenting need for modifications to ensure environment is accessible
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FOR RESIDENTIAL SITES ONLY (9-10)
Expectation |
Sources of Evidence of Compliance with Settings Rule
(This list is not exhaustive. Feel free to provide additional or alternative information to support the site's position.)
|
9) The unit or dwelling is a specific physical place that can be owned, rented, or occupied under a legally enforceable agreement by the individual receiving services, and the individual has, at a minimum, the same responsibilities and protections from eviction that tenants have under the landlord/tenant law of the State, county, city, or other designated entity. For settings in which landlord tenant laws do not apply, the State must ensure that a lease, residency agreement or other form of written agreement will be in place for each HCBS participant, and that the document provides protections that address eviction processes and appeals comparable to those provided under the jurisdiction's landlord tenant law. |
Implementation Evidence:
- Examples of person-centered plans and implementation strategies that document individual receipt of information regarding housing and eviction rights and detailing their understanding of the information
- Copies of residency agreements with protections to address eviction processes and appeals
- Evidence that provider has had training on the governing laws.
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10a) Each individual has privacy in their sleeping or living unit. |
Implementation Evidence:
- Examples of person-centered plans and implementation strategies that document individual education on privacy rights and/or consent to staff access in private spaces; cameras within the setting
- Evidence that individuals currently sharing a bedroom but who prefer a single room are being afforded an opportunity to choose another setting or bedroom within the current setting
- With permission, photos of sleeping and living units showing how privacy is maximized
- Example of a site working with an individual to create privacy opportunities that meet the individual's needs
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10b) Units have entrance doors lockable by the individual, with only APPROPRIATE staff having keys to door |
Implementation Evidence:
- Copy of lease or agreement specifying individual autonomy to close/lock bedroom door
- Copy of lease or agreement specifying individual will be given keys to the front door
- Evidence that the individual has had this explained to them
- Evidence that the individuals at the site have keys or have a documented modification
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10c) Individuals sharing units have a choice of roommates in that setting |
Implementation Evidence:
- Examples of person-centered plans and implementation strategies that address individual choice of roommate and/or housemate choice
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10d) Individuals have the freedom to furnish and decorate their sleeping or living units within the lease or agreement |
Implementation Evidence:
- Copy of lease or agreement specifying individual autonomy to arrange sleeping or living units to their personal preferences
- With permission, photos of living areas that are personalized to individuals
- Examples of Person-Centered Plans and implementation strategies that address individual choice of room décor and household items
- Photos of personalized spaces
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FOR BOTH CDS AND RESIDENTIAL (NEW)
Expectation |
Sources of Evidence of Compliance with Settings Rule
(This list is not exhaustive. Feel free to provide additional or alternative information to support the site's position.)
|
11. Any modification of the additional conditions, under §441.301(c)(4)(vi)(A) through (D), must be supported by a specific assessed need and justified in the person-centered service plan. The following requirements must be documented in the person-centered service plan
- Identify a specific and individualized assessed need.
- Document the positive interventions and supports used prior to any modifications to the person-centered service plan
- Document less intrusive methods of meeting the need that have been tried and did not work
- Include a clear description of the condition that is directly proportionate to the specific assessed need
- Include regular collection and review of data to measure the ongoing effectiveness of the modification
- Include established time limits for periodic reviews to determine if the modification is still necessary or can be terminated
- Include the informed consent of the individual
- Include an assurance that interventions and supports will cause no harm to the individual
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Implementation Evidence:
- 11a-h) Examples of person-centered plans and implementation strategies that include requirements from
- 11a-11h for individuals with modifications
- 11a-h) Evidence to support that individuals are educated on their required consent for modifications
- 11a-h) List of individuals served at the site that have modifications as described by this requirement
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