August 10, 2023
RE: Choate Developmental Center Repurposing Plan Special Report
Thank you to Equip for Equality's Independent Monitoring Unit for the ongoing, enhanced monitoring at the Choate Mental Health and Developmental Center (CMHDC) in Anna, IL. The well-being of people with developmental disabilities is my top priority - any mistreatment or misconduct in State-run or State-funded facilities is unacceptable. I have devoted significant time at CMHDC since I started as the DD Division Director in mid-June and will continue to commit time and energy to the crucial improvements that are underway on campus.
IDHS requested your additional monitoring, because of our respect for your independent lens, your expertise, and your undeniable commitment to progress for people with disabilities. We are grateful for your on-the-ground involvement and attention to CMHDC and all of IDHS' State Operated Developmental Centers.
Like you, I believe that every person with an intellectual or developmental disability deserves quality care, supports, and the opportunity to thrive. The goal for our Division of DD is to ensure that all individuals in Illinois with intellectual and developmental disabilities live in the least restrictive settings of their choice, and we are committed to building a system that realizes that aspiration.
Despite some very positive, substantive, and difficult changes in the last four years at the centers, even more rapid transformation of the intellectual and developmental disability system (I/DD) is necessary to support the person-first, community focused care that everyone deserves. In this regard, in March 2023, IDHS announced a set of unprecedented changes designed to enhance quality, safety, and staffing levels, and to facilitate more safe and successful resident transitions to home- and community-based settings.
This three-year effort demands deliberate, comprehensive planning to best serve residents and patients, staff, and the broader community. As you know, we have prioritized action in the following areas:
Culture of Safety
In March, IDHS appointed a Chief Resident Safety Officer to focus singularly on resident safety and to implement a Safety Plan to improve and ensure long-term quality and safety infrastructure in all SODCs. In addition, dozens of new indoor and outdoor security cameras are being installed at every SODC to deter misconduct and provide an added measure of accountability for residents and staff.
Another powerful tool we now have in our shared mission to prevent abuse and neglect in the SODCs is an enhanced penalty for obstructing investigations. The Residential Facility Safety and Support Act [Public Act 103-76 (Sen. Fine/Rep. LaPointe)] permanently bars employees who materially obstruct investigations into abuse or neglect from being able to work at our SODCs or in any other healthcare setting. As you know, this was signed into law by the Governor on June 9, after being crafted by the IDHS Office of the Inspector General, and strongly supported by IDHS and members of the Illinois General Assembly. We believe that this law will prevent abuses and encourage more cooperation in critical investigations.
Finally, IDHS is procuring and establishing an Electronic Health Record system. Once this time-intensive process has been completed, the EHR system will support more seamless case management and higher quality care for every resident and patient in IDHS' care.
Facilitating Resident Transitions
Over a three-year period, more than 100 individuals will successfully transition out of CMHDC into the living arrangement of their choice, including waiver-funded settings such as Community Integrated Living Arrangements (CILAs), Home Based Support Services (HBS), and Community Living Facilities (CLFs), as well as long-term care facilities such as private Intermediate Care Facilities (ICF-DDs) and other State Operated Development Centers (SODCs).
Since March 8, 19 residents have safely moved out of the facility or are completing pre-transition extended visits off campus. Fifteen have moved and four are completing pre-transition stays with community based residential settings outside of CMHDC. IDHS has been working with the Illinois Crisis Prevention Network's Support Service Teams to support every resident with their transition planning and implementation.
Building Community and Workforce Capacity
Unprecedented investments in Home and Community Based Service funding have been made. Additional CILA beds are opening in Southern Illinois and across the state, thanks in part to the highest-ever wage reimbursements for front-line workers (DSPs) in the community-based DD service ecosystem. We will continue to support these front-line workers and greatly appreciate the ongoing and significant efforts of our community partners and providers.
Of course, even as more SODC residents choose home- and community-based living options, achieving adequate staffing levels (with permanent, full-time--State employees) is crucial to the well-being of residents, patients, and staff. As we contend with the nationwide shortage of healthcare workers, the Department has taken numerous steps to accelerate hiring onsite, including filling vacancies through continuous postings of jobs, broadly advertising available jobs, hosting on-campus job fairs to allow potential employees to apply in real time, and working with the State's Department of Central Management Services to speed up hiring and increase starting wages for new employees.
These are serious, meaningful, and life-improving changes. (An addendum describing some key, related work in more detail follows this letter.) We fully recognize that while CMHDC and the I/DD system have already experienced immediate, beneficial changes (and home- and community-based I/DD service providers are receiving highest-ever funding levels), assessing the long-term impacts of such changes will take more time. Likewise, as we work to successfully change our system, we know that we must afford time to involve, understand, and respect the expertise and perspectives of our employees, residents, families, and guardians.
As you know, over the last several months, IDHS also engaged the Behavioral Health Workforce Center at Southern Illinois University School of Medicine (SIU SOM) to advance the transformation effort and make recommendations to address safety concerns, repurpose the CMHDC campus, and improve access to services in the community for people with developmental disabilities.
In July 2023, SIU issued a Phase One "Choate Transformation Report" that included an array of actionable recommendations that can help augment work already underway and inform further strategies moving forward. IDHS continues to work with SIU SOM, and as a part of the effort, we invite Equip for Equality to join us for continued dialogue with SIU SOM and the IDHS Office of the Inspector General about steps we can all support -- key areas of common ground that will most directly and effectively ameliorate the serious programmatic and operational concerns raised in your reports.
We appreciate your partnership and insight and believe that people of good faith working together with urgency in an "all hands on deck" approach can overcome the most daunting obstacles.
Thank you, as always, for your dedication to protecting and advocating for people with disabilities.
Sincerely,
Tonya Piephoff
Director
Division of Developmental Disabilities
Illinois Department of Human Services
ADDENDUM
Investment in Home and Community Based Services
Supporting more moves to home- and community-based settings will require continued, increasing investments in the home and community bases system of care. The State's FY24 budget (starting July 1, 2023) includes the highest-ever State investments in CILA (group home) settings and wage reimbursements for front-line workers in the community-based DD service ecosystem. This has encouraged providers to open additional CILA beds in Southern Illinois and across the state.
The current State (FY24) budget includes an all-time high commitment of more than $1.9 billion to home- and community-based I/DD services, supporting nearly 25,000 people in the three HCBS waiver programs: Adults, Children's Residential, and Children's Support.
Even more specifically, since 2019:
- Investment in CILAs, serving 11,000+ people, virtually doubled, from about $515 million to more than $1.02 billion.
- DSP wage reimbursements statewide have risen from $12.00/hour to $17.00/hour, which will increase to $19.50/hour effective January 1, 2024, or upon federal approval.
- DSP wage reimbursements in the Chicagoland area have risen from $12.00/hour to $19.55/hour, which will increase to $22.42/hour effective January 1, 2024, or upon federal approval.
SODC Resident Safety
Ryan Thomas was appointed IDHS' first-ever Chief Resident Safety Officer on March 6. Ms. Thomas brings over 16 years of regulatory compliance, resident and patient safety, and change management experience to her role. Ms. Thomas is charged with implementing safety improvements at all seven SODCs. The addition of Ms. Thomas follows security personnel increases that include: 4 security officer positions, 1 security chief, and 2 additional on-site investigatory employees. We will also be adding an onsite resident safety officer in the coming weeks.
Thirty-nine outdoor security cameras have been installed and activated at CMHDC and dozens more are being added in common indoor areas, where there is a low or no reasonable expectation of personal privacy (as opposed to resident bedrooms, restrooms, etc.). IDHS is carrying out additional security camera installation in all seven SODCs.
On June 26, a Safety Summit was hosted in Carbondale where CMHDC staff and leadership, IDHS staff, representatives from SIU School of Medicine, parents and guardians, advocacy groups, and local legislators developed safety action plans for the following safety topics: leadership and mid-management involvement and support for resident safety, communication about errors, handoffs and information exchange, reporting and responding to resident safety events, communication openness, and continuous improvement.
A staff townhall was held on July 7, 2023, to review the results from the culture of safety survey and the action plans developed to enhance the resident safety program. The implementation teams received related training throughout the month and are leading kickoff meetings in August.
In response to recent recommendations from the IDHS OIG, additional phones and locked bulletin boards were installed onsite to ensure employees and residents have access to safety information and the means to easily report abuse and neglect.
In partnership with the Illinois State Police, IDHS implemented additional training at CMHDC in March 2023 designed to improve reporting, safety, and care, including training for both frontline and direct care staff and management on abuse reporting, investigations, retaliation, and code of silence. Prior to the transformation, CMHDC employees received training from the Illinois Crisis Prevention Network on de-escalation techniques. In the last 6 weeks, key CMHDC staff were also trained in Skill System, a training for services to support individuals with behavioral needs, and CMHDC leadership were retrained in Root Cause Analysis completion.
