-# Kroh, Karen

Kroh, Karen -#From: Mochon, JulieSent: Wednesday, December 14, 2016 2:44 PM \i.S_ 5’kTo: Kroh, KarenSubject: FW: regulation feedbackAttachments: 6lOOdraft.feedbackJP,LLC.docx

From: Maria Welty Imailto: mwelty©independencerrofessionals.com]Sent: Wednesday, December 14, 2016 2:38 PMTo: Mochon, JulieSubject: regulation feedback

Hi Julie,

Attached is our feedback on the draft regulations. I used the template that was sent to us from our provider

organization, so you will have to scroll down to see which sections of the regulations have comments. The last

section with comments is 6100.571 fee-scheduled rates.

Thank you for your time and consideration.

Maria Welty, M.Ed.Independence Professionals412-916-5253

This electronic message and its attachments may include information from Independence Professionals, LLC

that is confidential and may be protected under federal and/or state law. This information is intended to be

for the use of the intended addressee only. The improper use of this information is prohibited. If you have

received this e-mail in error, please notify the above sending party and immediately discard the above

message.

1

Comments TemplateChapter 6100

Citation: 6100.1. Purpose (a)

Discussion:

Recommendation:

Citation: 6100.2. Applicability

Discussion:

Recommendation:

Citation: 6100.3. Definitions

Discussion:

Recommendation:

Citation: 6100.41. Appeals

Discussion:

Recommendation:

Citation: 6100.42. Monitoring compliance

Discussion:

Recommendation:

Citation: 6100.43. Regulatory waiver

Comments on Chapter 6100— Support for Individuals with an Intellectual Disability orAutismDatePage 2 of 36

Discussion:

Recommendation:

Citation: 6100A4. Innovation project

Discussion:

Recommendation:

Citation: 6100.45. Quality management

Discussion:

Comments on Chapter 6100— Support for Individuals with an Intellectual Disability or AutismDatePage 3 of 36

Recommendation:

We agree that every agency should do their best to provide the highest quality services that

they possibly can provide. We do not believe that regulating quality management will have

the effect that you are seeking because most people already want to do the best job that they

can, and are collecting all of the data requested informally for practical purposes. Nobody

wants high incidents, grievances, and turn-over. Quality management within regulations that

guides people as to how to achieve that goal will give you compliance. Qualitymanagement

because agencies aren’t overburdened with compliance leads to quality programs. There are

currently almost 1000 agencies listed in the services & supports directory in hcsis for ODP.

Since there are no limits on the amount of agencies who can provide services in the IDSystem, and this can increase the amount of programs who must be monitored (whichincreases costs to the system), perhaps we should be allowing the competition betweenagencies to pressure those agencies who may need outside motivation. From our experience,

as we only do Home & Community Hab (Unlicensed) and have been doing it for 16 years

(before our contract with the government for the waiver), quality management requires

individual agencies to look closely at their own programs. We use to be able to require abachelor’s level credentials and we had low turn-over. We also use to conduct satisfaction

surveys from employees and families, which always resulted in a lot of very positive

feedback. Since we took a cut in our rate 7 years ago and only received pennies in increases

since then, we have had to take on increasingly more work to cover increasing costs due tocost of living increases, labor law changes, regulations changes, etc. over the years. This has

all employees working for minimal pay and supervisory staff (who provide the support tothem) all spread very thin. We recently began conducting exit interviews because we started

losing more and more people before they even began working with individuals. This has

historically not been an issue that our agency faced. The following are comments that were

made by employees who have left:• Left for full time work (as Home & Community Hab is typically hard to staff full-

time)• Couldn’t make enough money

• They did not feel that the compensation was reasonable for what was expected — citedexcessive responsibility for medical and behavioral concerns, wear and tear on car,unreliable income due to chronic cancellations by individuals and their families, riskof bringing bed bugs home (this is getting more common), and even in some cases,unappreciative individuals and families.

All of this said, we had a quality program that permitted us to hire skilled people and allowed

us autonomy in making decisions that worked for us that worked well. It only required us to

pay people a fair rate for what was expected, and allowed us to solve our own problems.

Increasing expectations on agencies to provide a uniform systemic approach to reporting

quality, many of whom are already informally collecting this data for themselves for practical

purposes, will simply consume more resources. Currently, we already have quality controlmeasures in place to speak with individuals and their families on a quarterly basis to givethem opportunities to share positives and to voice their concerns. The biggest concern forevery person with whom we speak is the frustration in the turn-over in staff. They want

regular staff who stay with the job. We lost 13 cases this year because of staffing issues.Hitorically, we only lost a case because a person passed away, or s/he was no longer eligible

for services (i.e. moved into a group home.) We rarely had dissatisfied families. The biggest


complaint with staff that leads to turn-over in the job is the low pay for everything that isexpected of them. When we seek feedback for ways to improve the job from our long-termstafi, they have stopped giving us feedback. They don’t feel that there is money, or anythingthat we can do.

Perhaps unlicensed services can be exempt from this expectation.

Citation: 6100.46. Protective services

Discussion:

Recommendation:

Citation: 6100.47. Criminal history checks

Discussion:

Recommendation:

Citation: 6100.48. Funding, hiring, retention and utilization

Discussion:

Recommendation:

Citation: 6100.49. Child abuse history certification

Discussion:

Recommendation:

Citation: 6100.50. Communication V

Discussion:

Comments on Chapter 6100— Support for Individuals with an Intellectual Disability or Autism

DatePage 5 of 36

Recommendation:

Citation: 6100.51. Grievances

Discussion:

Recommendation:

Citation: 6100.52. Rights team

Discussion:


Recommendation:While we do agree that the rights of the disabled must be protected, we do not believe

that adding additional expectations, including the creation of a rights team that must meetquarterly, will improve the protection of anybody’s rights. Additionally, it appears that therights teams are made up of the affected individual, a person they designate, the individual’ssupport coordinator, etc. This could create as many different rights teams as there areindividuals for whom the agency supports. Furthermore, it specifies that the rights team mustdiscover and resolve the reason for the individual’s behavior. Every agency should already bedoing this, and if they are unable to identify the reason for the behavior, then behavior supportservices are usually recommended in order to complete a full analysis of the situation. It is inevery agencies best interest to understand and resolve any problematic behavior without itbeing spelled out in a regulation or identified by a rights team, if not because it is the rightthing to do, then because it is the only way to provide staffing for challenging cases whereproblematic behavior is exhibited. Attempting to regulate every decision that providers mustmake, will not provide better support services. This is top down management (of which well-run organizations have all moved away from) and results in increased rationalizations, andless resourcefulness.

From a slightly different perspective, I am a special educator with a master’s degree in specialeducation with an emphasis on behavioral disorders. I provided emotional support for thosediagnosed with serious emotional disturbances, and worked with the most challenging ofcases in Allegheny county. I worked within a very reputable program, and experienced agreat deal of success. I left that job when I started my family, and wanted control over myschedule. For the majority of the population whom we serve, behavioral concerns are not anissue. However, for those who do exhibit problematic behavior, I can tell you that one of thekey concerns is helping them to understand their role in their mental health, their progress,their success and their happiness. When we overemphasize their rights without the balanceof an expectation of responsibility we are creating great imbalance. Balance is needed forhealthy behavior, and healthy behavior is essential in treating mental health. While I dounderstand that it is most likely not within Pennsylvania’s ability to do so, I believe that muchcan be addressed from a behavioral and mental health perspective if we only placedexpectations on those who ask taxpayers to support them. From a BSC perspective, I can tellyou that expectations are very powerful. Nancy Richey, policy maker for ODP, gave apresentation to our group on this very same subject matter and quoted research proving thenecessity of expectations for the success of our disabled population. When there are noexpectations and rarely accountability, then this very abstract concept of responsibility ischallenging to teach. This problem isfurther exaggerated when unskilled staffare the oneswho provide the support services to them. We don ‘t need more regulations trying to train andcontrol unskilledpeople. We need less regulations, freedom to use professionaljudgment.and money to hire more qualfledpeople.

From a BSC perspective, I am asked to look at the complex cases that are becoming the normin our system and the same ones that are the most expensive and challenging to support. Myexperience is that people whom we serve are no longer the ones who primarily are beingdischarged from institutions, where maladaptive behavior may have been learned as a means

Comments on Chapter 6100— Support for individuals with an Intellectual Disability or AutismDatePage 7of36

to get their needs met or to protect themselves. These complex cases are a younger

generation, who live at home, and who have many years ahead of them of needed support.

The 11) System is struggling with being able to staff its programs with its current rates, and

PA is only servicing 28% of the disabled population. We must expect everybody, including

those who are benefitting from the system directly and who have the most to lose when the

system fails to function in a healthy way— and many of whom are very capable of

understanding, to help make this system work from a long term perspective. I am not

suggesting that disabled people who have to learn responsibility are bad people, I am saying

that disabled adults are as complex as you and I, and there are many disabled people sitting in

our prisons today who would have been far better served if we were permitted the tools to

teach. I suspect that the stakeholders with whom you frequently work are the families and

disabled individuals who do not fall in the category of families of whom I am referring.

Again, while Pennsylvania may not be able to implement any suggestions that I make,

I believe that there is value in educating anybody who is in the position to advocate for

change now or in the future. Expectations should be spelled out by the team, which includes

the disabled individuals themselves, as to how they are going to assist with ensuring the long

term financial sustainability of the system for all, and it should be included in every ISP.

Agreement of Responsibilities that accompanies all services could and should include:

1. Must follow through on services (as this makes it incredibly challenging to staff

positions and is costly to agencies who must constantly replace staff)

2. Must take responsibility for poor choices (maladaptive behavior) and, at minimum,

each individual should be expected to participate in a conversation to process throughany issues that arise when maladaptive behavior is exhibited so they can learn fromtheir mistakes and identify healthier behavioral alternatives

3. Must do best to work on identified goals4. Must make the most affordable choices that are appropriate, including the most

affordable living options, family planning, etc.

5. ivlust use natural supports first when appropriate

6. Must give back to the community thru volunteerism

We must look closely at these complex cases that are becoming increasingly common in the

system, and learn from them. We must remember that non-disabled people have natural

boundaries on our choices, and removing all expectation of responsibility is removing

boundaries necessary for healthy functioning. When somebody lives alone in the community

because they are supported with entitlement money and services, and they choose to have a

baby to increase their food stamps, while unable to understand why any of their entitlement

money should be budgeted for their baby, we are creating the problems that exists within the

system. Limited funds gets spread even thinner, and the efficacy of services continues to be

sacrificed. Emphasizing one’s rights while placing no expectations on somebody who has

never been taught responsibility can cost the system millions of dollars annually, and is

slowly creating different problems with not only the sustainability of the ID system, but in our

mental health facilities, prisons, foster care programs, public schools, etc.

Comments on Chapter 6100— Support for Individuals with an Intellectual Disability or AutismDatePage8of36

Citation: 6100.53. Conflict of interest

Discussion:

Recommendation:

Citation: 6100.54. Recordkeeping

Discussion:

Recommendation:

Citation: 6100.55. Reserved capacity

Discussion:

Recommendation:

Citation: 6100.81. HCBS provider requirements

Discussion:

Recommendation:

Citation: 6100.82. HCBS documentation

Discussion:

Recommendation:

Citation: 6100.83. Submission of HCBS qualification documentation

Discussion:

Comments on Chapter 6100 — Support for Individuals with an Intellectual Disability or AutismDatePage 9 of 36

Recommendation:

Citation: 6100.84. Provision, update and verification of information

Discussion:

Recommendation:

Citation: 6100.85. Ongoing HCBS provider qualifications

Discussion:

Recommendation:

Citation: 6100.86. Delivery of HCBS

Discussion:

Recommendation:

Citation: 6100.141. Annual training plan

Discussion:

Recommendation:

Citation: 6100.142. Orientation program

Discussion:

Recommendation:


Citation: 6100.143. Annual training

Discussion:

Recommendation:From a system perspective, it appears that the streamlining of regulations is going to be costeffective for the system as a whole, and this makes sense to us as an agency. However, as anagency who only provides Home and Community Hab and Behavior Supports, this reductionin duplication of the regulatory processes will, not save our particular agency on any costs, andwe are extremely concerned about how we will cover these additional costs for training. Ifrates are increased for 2017-2018 (and we are only hopeful that they will be) we need to notonly cover this signUlcant additional cost of training, but we must be able to offer acompetitive wage so that we can continue to hire staff.

Additionally, we agree that training is incredibly beneficial to staff, and is key inhelping staff to provide the best services possible. However, our current turn-over rate is righton average of 30% -similar to other agencies, but this number increases if we include staffwhom we hired who quit after training and never even started work.2016—(asofll/30/16) 39%2015 36%2014 37%2013 34%All of this said, we are very concerned about how we are going to cover this increase in costsfor training for our current staff, and worry about the excessive lose incurred from 24 hours oftraining for so many staff who never stay beyond training. Additionally, each year from 2013to 2015, only 52% per year stayed with the position beyond the year. The costs to cover 24hours of training for almost half the staff to only work for one year does not seem to be agood investment. Furthermore, the majority of staff are part-time employees, and expecting24 hours of training from somebody who has 15 hours/week available to work, will onlycreating more challenges in recruitment. Finally, we have had several job candidates whoshowed up for interviews with certificates from trainings from other jobs in the field.However, when questioned on the information, the retention of the information from thetraining was so poor that we chose not to offer them jobs. Money would be far better investedin offering higher rates in order to attract higher quality candidates who come in withcredentials rather than bringing in mediocre candidates who can’t retain and apply theinformation for which they are trained.

Perhaps unlicensed services can be exempt from this expectation.

Citation: 6100.144. Natural supports

Discussion:

Comments on Chapter 6100— Support for Individuals with an Intellectual Disability or AutismDatePage 11 of36

Recommendation:

Citation: 6100.181. Exercise of rights

Discussion:

Recommendation:

Citation: 6100.182. Rights of the individual

Discussion:

Recommendation: V

Citation: 6100.183. Additional rights of the individual in a residential facility

Discussion:

Recommendation:

Citation: 6100.184. Negotiation of choices

Discussion:

Recommendation:

Citation: 61 00.185. Informing of rights

Discussion:

Recommendation:


Citation: 6100.1 86. Role of family and friends

Discussion:

Recommendation:

Citation: 6100.221. Development of the PSP

Discussion:

Recommendation:

Citation: 61 00.222. The PSP process

Discussion:

Recommendation:

Citation: 6100.223. Content of the PSP

Discussion:

Recommendation: This is where expectations, as noted above, should go. Again, thedisabled individual is part of the team, and can provide feedback as to how s/he feels s/he cando their part to assist in, not only the financial sustainability of the system, but in better use offunds in order to assist in hiring qualified staff.

Citation: 6100.224. Implementation of the PSP

Discussion:

Recommendation:


Citation:

Discussion:

6100.225. Support coordination and TSM

Recommendation:

Citation: 6100.226. Documentation of support delivery

Discussion:

Recommendation

Citation: 6100.261. Access to the community

Discussion:

Recommendation:

Citation: 6100.262. Employment

Discussion: V

Recommendation:V

Citation: 6100.263. Education

Discussion: V

Recommendation:

Citation:

Discussion:

61 00.301. Individual choice

Comments on Chapter 6100 — Support for Individuals with an Intellectual Disability or AutismDatePage 14 of 36

Recommendation:

Citation: 6100.302. Transition to a new provider

Discussion:

Recommendation:

Citation: 6100.303. Reasons for a transfer or a change in a provider

Discussion:

Recommendation:

Citation: 6100.304. Written notice

Discussion:

Recommendation:

Citation: 6100.305. Continuation of support

Discussion:

Recommendation:

Citation: 61 00.306. Transition planning

Discussion:

Recommendation:


Citation: 6100.307. Transfer of records

Discussion:

Recommendation:

Citation: 6100.341. Use of a positive intervention

Discussion: Support. Good change of title from “Safe Behavior Management”

Recommendation:

Citation: 6100.342. PSP

Discussion:

Recommendation:

Citation: 6100.343. Prohibition of restraints

Discussion: Title can be misleading to appear that no restraints are allowed, ever

Recommendation: Change title to “Prohibition of certain types of restraints.”

Citation: 6100.344. Permitted interventions

Discussion:

Comments on Chapter 6100— Support for Individuals with an Intellectual Disability or AutismDatePage 16of36

Recommendation:

We do not use physical restraints in our organization, but I can tell you as somebody who hasbeen trained in therapeutic crisis intervention and who has used physical restraints properly —

for safety only- you cannot put a time limit on the restraint. When somebody is exhibitingunsafe behavior that prompts a person to implement such a procedure, then the individual nolonger has self-control. You must maintain the restraint until the individual is breathingnormally, and is in control of themselves. Dictating a timeframe as to when that must occurcould create a dangerous situation. Some people can gain control quickly, while others whoare more intense can take much longer. When restraints (along with proper “processingtechniques”) are implemented correctly, I have witnessed them being the turning point inmany people’s lives.

Citation: 6100.345. Access tO or the use of an individual’s personal property

Discussion:

Recommendation:

Indicating that a person’s personal funds cannot be used as payment for damaged propertyunless consent is obtained is very dangerous. If a person is not held accountable for theiractions, then they learn, in very concrete terms, that their actions are not directly related totheir outcomes. If they believe that their actions are not directly related to their outcomeswhen it comes to maladaptive behavior, then how can we teach them that their actions aredirectly related to their outcomes when it comes to their mental health, progress, success, andhappiness? If we encourage responsible behavior, and they do not cooperate, then again, theylearn in very concrete terms, that they are not responsible for themselves. Not to mention,nothing solidifies maladaptive behavior more effectively than intermittent reinforcement.Responsibility is imperative for one’s mental health, success, and for the sustainability of thesystem in general. This is an abstract concept that is challenging to teach. To not permit anagency to capitalize on a natural situation is removing the most effective tool that changesbehavior, and healthy behavior is a prerequisite to mental health. It may not be “normal” tomake a non-disabled peer pay for something that they break, but our non-disabled peers arenot asking taxpayers to pay for support services to teach them the skills to live an everydaylife.

Citation: 6100.401. Types of incidents and timelines for reporting

Discussion:

Comments on Chapter 6100— Support for Individuals with an Intellectual Disability or AutismDatePage 17of36

Recommendation:

Citation: 6100.402. Incident investigation

Discussion:

Recommendation:

Citation: 6100.403. Individual needs

Discussion:

Recommendation:

Citation: 61 00.404. Final incident report

Discussion:

Citation:

Discussion:

Recommendation:

Citation: 6100.441. Request for and approval of changes

Discussion:

Recommendation:

Recommendation:

6100.405. Incident analysis

Comments on Chapter 6100— Support for Individuals with an Intellectual Disability orAutismDatePage 18 of36

Citation: 6100.442. Physical accessibility

Discussion:

Recommendation:

Citation: 6100.443. Access to the bedroom and the home

Discussion:

Recommendation:

Citation: 6100.444. Lease or ownership

Discussion:

Recommendation:

Citation: 6100.445. Integration

Discussion:

Recommendation:

Citation: 6100.446. Facility characteristics relating to size of facility

Discussion:

Recommendation:

Citation: 6100.447. Facility characteristics relating to location of facility

Discussion:

Comments on Chapter 6100— Support for Individuals with an Intellectual Disability or AutismDatePage 19 of36

Recommendation:

Citation: 61 00.461. Self-administration

Discussion:

Recommendation:

Citation: 6100.462. Medication administration

Discussion:

LRecommendation:

Citation: 61 00.463. Storage and disposal of medications

Discussion:

Recommendation:

Citation: 6100.464. Labeling of medications

Discussion:

Recommendation:

Citation: 61 00.465. Prescription medications

Discussion:


Recommendation:

Citation: 6100.466. Medication records

Discussion:

Reóommendation:

Citation: 6100.467. Medical errors

Discussion:

Recommendation:

Citation: 6100.468. Adverse reaction

Discussion:

Recommendation:

Citation: 6100.469. Medication administration training

Discussion:

Recommendation:

Citation: 6100.470. Exception for family members

Discussion:

Recommendation:


Citation: 6100.481. Department rates and classifications

Discussion:

Recommendation:

Citation: 6100.482. Payment

Discussion:

Recommendation:

Citation: 6100.483. Title of a residential building

Discussion:

Recommendation:

Citation: 6100.484. Provider billing

Discussion:

Recommendation:

Citation: 6100.485. Audits

Discussion:

Recommendation:

Citation: 6100.486. Bidding

Discussion:

Comments on Chapter 6100— Support for individuals with an Intellectual Disability or AutismDatePage 22 of 36

Recommendation:

Citation: 6100.487. Loss or damage to property

Discussion:

Recommendation:

Citation: 6100.571. Fee schedule rates

Discussion:


Recommendation:

While we agree that money must be used prudently to support the most people in the mostefficient way, much can happen in three years that could have a significant impact on theproviders’ abilities to recruit staff. Additionally, there are many additional costs that appearto get overlooked. To start, costs include an expectation of participation in ISP meetingswithout an ability to bill for our time. There isn’t a business out there who is permitted torequire their employees to work without paying them. Additionally, staff participation in theSIS is important if we want the most accurate information in some cases, yet again, this is notbillable time. Furthermore, often times staff must work with the disabled for short periods oftime, because it is what they need and is what is indicated in their ISP. Staff will then take onadditional caseloads in order to create a reasonable work schedule. However, we cannot billfor time between cases. Again, this is time that staff must work that is not billable. Finally,additional time is needed to communicate with supervisors & peers; complete paperwork, setup schedules, problem solve through behavioral concerns etc. that is not billable. Ratessimply must reflect these additional challenges.

When we started our business 16 years ago (but were not under government contract), ourservices were the same. We completed assessments, ‘wrote goals, kept notes, collected data,and monitored progress. Our employees earned an average of $11 .00/hour and we were ableto require a Bachelor’s degree. We had low turn-over, and completed satisfaction surveysthat always yielded very positive feedback from employees, individuals, and families.Today, 16 years later, staff are earning an average of$12.00/ hour, despite the increase incost of living because it’s what we can afford with the current rates and increasingexpectations in both regulations and labor laws. We have exceedingly high unemploymenttaxes, which often times goes unnoticed, because we have to employ primarily part-time.employees, and unemployment taxes are paid on the first $7,000 a person makes, so we paythis tax on much of the wages that we pay out. We continue to seek out candidates withdegrees who are interested in fuller schedules, but we often times have to lower our standardsfor somebody with potential to be taught and who is willing to work at least one case. Ourturn-over rate is high as we don’t have much of an employment pooi from which to draw.The only way to get decent candidates who are qualified is to sell them on the job with ourenthusiasm, and seeking people who are not driven by money. This gets them started, butonce they go through our orientation process, they begin to get discouraged when they realizethat there is an incredible amount of responsibility and, because of the excessive regulations,very little autonomy and flexibility. (Flexibility in meeting frequency and duration of thedisabled individual needs does not equal flexibility for staff because this flexibility stillrevolves around participants’ needs.) Because they have chosen to try the job to dosomething meaningful, they often times use their creativity and innovation to problem solvethrough issues, but often times get discouraged and lose motivation when they show up forwork to be told from mom that “John is tired, and doesn’t want to get out of bed today.”Since there are no expectations placed on the disabled individuals themselves, staff are notalways treated as professionals, and often times feel like glorified babysitters. This takes themeaning out of the job for them, and draws them to the more enticing customer service part-time jobs in the market today where they can make the same amount of money; they don’thave to concern themselves with cancellations; they have flexibility, and full autonomy.Many larger organizations have normalized and substantiated these customer service “workfrom home” jobs by providing benefits and full autonomy with no wear and tear on their car,


and we simply cannot compete.

Below are our hiring statistics:

9/20/16 (Habilitation Specialist — part-time job at $1 1.00/br)67 people viewed the ad8 people applied3 interviews were offered0 people accepted the offer to interview

10/3/16 (Habilitation Specialist — part-time j oh at $11 .00/br)

202 people viewed the ad9 people applied7 offers were made for interviews4 people interviewed3 job offers were made1 accepted the j oh but didn’t show up for training

10/25/16 (Habilitation Specialist (floater)— part-time job at $14.00/br)Decided to hire a floater (fill in staff) at a higher rate despite need for regular staffbecause we thought that would bring in at least temporary staff who we can move arounduntil we found pennanent candidates507 viewed the ad36 people applied14 interviews were set up (encouraged 8 to work as regular Hab first at $1 1.00/hour)8 offers were made2 people accepted1 didn’t show up for training1 staff trained

November 28th We added that it had the potential to become full time. (We even changed thename of the position to get the attention of people who may not think that they have thecredentials from Habilitation Specialist to Life Mentor. We did this awhile back.)

367 viewed the ad36 applicants were screened22 replied to the screening10 phone calls followed up for interviews4 people scheduled after discussing the job in more detail2 people didn’t show up for the interview2 people cancelled the day of the interview0 offers were made

We have reached a point where our staff who have been with us since the beginning (16years), and who have been helping us to be enthusiastic to get people in for the job, arecalling it quits. They have asked to take a break from trying to recruit and train. Oursupervisors who have all been us for years are ready to step down from their positionsbecause they are frustrated with having to continuously contact families to let them know that


the new staff whom they just met is quitting, and there is turn-over again. They all feeldefeated.

The rates must not only be “refreshed” every three years. Rates need to be re-evaluatedannually, and they need to include cost of living increases every single year. They absolutelymust be reflective of what is expected and must be competitive with other businesses, or thisnew paradigm shift of encouraging everybody to keep their loved ones at home for as long aspossible with support in home will simply not work. For the first time in 16 years, we arestruggling with increasing units in order to increase revenue to help cover additional costsbecause we simply cannot hire people. We share this information as ones who have been inthe field of Special Education, and have experienced a great deal of success in our work foralmost three decades, not for ourselves, but for those disabled individuals whom we serve andtheir families who will depend upon this system for years to come.

Citation: 6100.641. Cost-based rate

Discussion:

Recommendation:

Citation: 61 00.642. Assignment of rate

Discussion:

Recommendation:

Citation: 6100.643. Submission of cost report

Discussion:

Recommendation:

Citation: 6100.644. Cost report

Discussion:


Recommendation:

Citation: 6100.645. Rate setting

Discussion:

Recommendation:

Citation: 6100.646. Cost-based rates for residential habilitation

Discussion:

Recommendation:

Citation: 6100.647. Allowable costs

Discussion:

Recommendation:

Citation: 6100.648. Donations

Discussion:

Recommendation:

Citation: 61 00.649. Management fees

Discussion:

Recommendation:


Citation: 6100.650. Consultants

Discussion:

Recommendation:

Citation: 6100.651. Governing board

Discussion:

Recommendation:

Citation: 6100.652. Compensation

Discussion:

Recommendation:

Citation: 61 00.653. Training

Discussion:

Recommendation:

Citation: 61 00.654. Staff recruitment

Discussion:

Recommendation:

Citation: 6100.655. Travel

Discussion:


Recommendation:

Citation: 6100.656. Supplies

Discussion:

Recommendation:

Citation: 6100.657. Rental equipment and furnishing

Discussion:

Recommendation:

Citation: 6100.658. Communication

Discussion:

Recommendation:

Citation: 6100.659. Rental of administrative space

Discussion:

Recommendation:

Citation: 6100.660. Occupancy expenses for administrative buildings

Discussion:


Recommendation:

Citation: 6100.661. Fixed assets

Discussion:

Recommendation:

Citation: 61 00.662. Motor vehicles

Discussion:

Recommendation:

Citation: 6100.663. Fixed assets of administrative buildings

Discussion:

Recommendation:

Citation: 61 00.664. Residential habilitation vacancy

Discussion:

Recommendation:

Citation: 6100.665. Indirect costs

Discussion:

LRecommendation:


Citation:

Discussion:

6100.666. Moving expenses

Recommendation:

Citation: 6100.667. Interest expense

Discussion:

Recommendation:

Citation: 6100.668. Insurance

Discussion:

Recommendation:

Citation:

Discussion:

Citation:

Discussion:

6100.669. Other allowable costs

6100.670. Start-up cost

Recommendation:

Citation: 6100.671. Reporting of start-up cost

Discussion:


Recommendation:

Citation: 61 00.672. Cap on start-up cost

Discussion:

Recommendation:

Citation: 6100681. Room and board applicability

Discussion:

Recommendation:

Citation: 61 00.682. Support to the individual

Discussion:

Recommendation:

Citation: 6100.683. No delegation permitted

Discussion:

Recommendation:

Citation: 6100.684. Actual provider room and board cost

Discussion:


Recommendation:

Citation: 6100.685. Benefits

Discussion:

Recommendation:

Citation: 61 00.686. Room and board rate

Discussion:

Recommendation:

Citation: 6100.687. Documentation

Discussion:

Recommendation:

Citation: 6100.688. Completing and signing the room and board residencyagreement

Discussion:

Recommendation:

Citation: 6100.689. Modifications to the room and board residency agreement

Discussion:


Recommendation:

Citation: 6100.690. Copy of room and board residency agreement

Discussion:

Recommendation:

Citation: 6100.691. Respite care

Discussion:

Recommendation:

Citation: 6100.692. Hospitalization

Discussion:

Recommendation:

Citation: 6100.693. Exception

Discussion:

Recommendation:

Citation: 6100.694. Delay in an individual’s income

Discussion:

Recommendation:


Citation: 6100.711. Fee for the ineligible portion of residential habilitation

Discussion:

Recommendation:

Citation: 6100.741. Sanctions

Discussion:

Recommendation:

Citation: 6100.742. Array of sanctions

Discussion: If these are not licensing regulations, the language should not be sofocused on corrective action.

Recommendation: Change title to “Remediation.”

Citation: 6100.743. Consideration as to type of sanction utilized

Discussion:

Recommendation:

Citation: 61 00.744. Additional conditions and sanctions

Discussion:

Recommendation:

Citation: 61 00.801. Adult autismwaiver


Discussion:

Recommendation:

Citation: 6100.802. Agency with choice

Discussion:

Recommendation:

Citation: 6100.803. Support coordination, targeted support management andbase-funded support coordination

Discussion:

Recommendation:

Citation: 6100.804. Organized health care delivery system

Discussion:

Recommendation:

Citation: 6100.805. Base-funded support

Discussion:

Recommendation:

Citation: 6100.806. Vendor goods and services

Discussion:


Recommendation:

cc: Nancy Thaler, Deputy Secretary, Department of Human Services, ODP

-# Kroh, Karen

Documents

Transcript of -# Kroh, Karen