HBS Public Recomendations

The Division of Developmental Disabilities convened a stakeholder workgroup to review the Home Based Services (HBS) program, make recommendations to update and improve the service to align with federal regulations and ensure a person centered planning process. After many months of meetings and thoughtful discussion, the final recommendations and a brief summary of the Division's responses are shared below.

# Workgroup Recommendation Division Response
1 Continue Service Facilitation (SF) as an administrative function. There is no additional funding to cover the cost of continuing SF in addition to the monthly allotment for all service recipients.
2 Design and implement a robust communication strategy to fully inform home based service participants of their duties and responsibilities currently performed by Service Facilitators, and that if they choose not to purchase this service, they will be responsible for these activities. Detail what duties conflict free case management will and will not perform. The Division and the Independent Service Coordination (ISC) agencies will educate persons receiving services as well as their families through direct mailing, communication bulletins, website, webinars, meetings, etc.
3 Finalize a comprehensive list of SF current job duties and determine how essential services will be divided. Consideration must be given to those who are new to services or established in the system. The Division is finalizing a program description that delineates the roles of responsible parties.
4 Create an additional flash card to include in the Guide to Developmental Disabilities System that describes SF. The grant that funded the original set of flash cards has ended. The Division will choose other communication tools to communicate the changes in SF. See #2.
5 Create a checklist summarizing DDD and CMS' expectations for all participants in self-directed services which they are required to sign off on. See #3. The workgroup will be developing a document that details expectations for ISC's to review annually with the recipients of home based services.
6 For those participants who opt out of SF, DDD must ensure a minimum level of safety and well being touch points. The Division will ensure the safety and well being of all participants in all waiver services through multiple avenues of monitoring: ISC, Bureau of Quality Management (BQM).
7 After participant chooses SF, provider would have a service agreement (just like other services DT, PT, etc.). If a participant chooses SF services there will be a service agreement completed. This agreement does include a general provision that states: "The Individual or the Service Provider may, on 30 calendar days written notice of their intention to do so, terminate this agreement. This notification requirement may be waived for cause, such as allegations of abuse or neglect, non-performance, fraud, or unsatisfactory performance. In such cases, cancellation may be immediate."

Service recipients, as well as family members, should receive training about what they can do with HBS funds

- what services are available and how to use funds to support person centered plan.

A standard set of reference documents are being finalized to fully explain responsibilities and expectations of the HBS program. See #2, 3.
9 Solicit information from other states regarding SF duties. There has been ongoing research of other states and their practices. The National Association of State Directors of Developmental Disabilities Services (NASDDDS) has assisted in this process. NASDDDS is a non profit, professional organization dedicated to improving and expanding public services to people with intellectual and other developmental disabilities in the United States.
10 Recommend a name change "Family Support." What this service will be called is currently under discussion with our federal regulatory agency, Centers for Medicaid and Medicare Services (CMS).
11 Strengthen expectations of family support: guidelines, SF component, and fully capture definition of service facilitation. See #8.
12 DDD needs to clearly define the purpose, goals, functions, and intent of the HBS program. See #3, 5, 8.
13 DDD needs to actively assure that the implementation of program services reflects the qualities/purpose defined by the Division. All of the Division's monitoring activities will be revised based on approval of the waiver.
14 For program planning, evaluation, and utilization review efforts, have a more robust data collection and reporting system regarding the use of HBS resources (explore what data is currently available and what additional data should be collected). Specifically separating adults/children reports. The data subcommittee met and reviewed the data that is available as well as offered suggestions for future data collection. The Division will continue to look at improvements in reporting systems as our IT systems improve.
15 In the area of fraud or financial exploitation: Establish a process that is proactive in educating participants on the intended use of the award and their responsibilities, develop a clear definition of financial exploitation. See #8.
16 In the area of fraud or financial exploitation: Consider a process of requiring participants in (self directed) to reapply every five years to assure the appropriateness of the services. Federal regulations require an annual redetermination which the ISC agencies complete. See #5.
17 Establish a clear reporting strategy/procedure to follow in suspected fraud or financial exploitation cases. The Division has a clear reporting strategy to follow that is reviewed annually with service participants and family members using the RIGHTS OF INDIVIDUALS form (IL462-1201). Contact agencies for complaints are listed on page 3 of this form.
18 During a fraud investigation develop a set of safety measures to ensure individual's safety, health, and well being, and help achieve outcomes identified by the person centered plan (PCP). Possible short term measures could include: increased monitoring, mandatory training, re-evaluating appropriateness of self directed or HBS support. The Division relies on the specific safeguards built into the procedures of agencies that investigate and follow up on complaints that occur at home or at a developmental training site: Adult Protective Services (APS), and Office of Inspector General (OIG). See #8.
19 Establish a clear process for Independent Service Coordination (ISC) agencies to follow when HBS resources are not being used to support person centered plan (PCP) priorities and/or progress towards outcomes is not noted. The Division has a current reporting strategy for financial fraud. See #17. The Division will develop a clear process for the ISC agencies to follow when person centered priorities and/or outcomes are not being addressed.
20 Create a clear process in which families report on how the award has assisted the individual in advancing their person centered plan priorities (documentation for follow up, action, and outcomes). The Division agreed that more discussion, as well as research of other states is needed regarding implementation strategies and documentation for self- directed services. All efforts will coordinate with the Life Choices Initiative.
21 Fully clarify the responsibilities of personal support workers (PSW) in the self directed model. To be able to support PSW and participant receiving services there needs to be some training requirements. The committee supports those recommendations in the 2011 workgroup regarding training for all new PSWs.Consider a grandfather status for those PSWs already working in the self directed model. The Division is not planning to implement this recommendation at this time. Further discussion and information will be forthcoming.
22 Develop an involuntary termination process for proven fraud/financial exploitation cases with appeal process. The current waiver notes the process of involuntary termination and that if in self-directed services can be assigned an agency provider upon proven fraud. See #17 and #18.