ADAPT’s demands of Colorado Department of Health Care Policy and Financing during the Fall National ADAPT Action, 2018

Colorado Choice Transitions

  1. Include transition services as an HCBS waiver benefit, exempt CILs from the requirement to become a case management agency, or remove any requirement that results in an inherent conflict between advocacy and case management and eliminate the hard cap on transition hours.
  2. Remove the licensure requirement for ILST.
  3. Include lived experience as a minimum qualification for all services.
  4. All providers shall be required to implement the independent living philosophy.

Conflict Free Case Management

  1. Work with ADAPT, Arcs, CCDC and others to address the problems with I/DD providers determining whether they will serve a consumer rather than allowing the consumer to be given the choice.
  2. Address problematic issues in the appeals and due process rules.
  3. Clarify that all cost containment language MUST is clear that cost containment is done on an AGGREGATE basis, not individually, and that some people may cost more in the community but are still allowed to live in the community as long as AGGREGATE service costs are less than institutionalization. This means all clients together in the community cost less than if all clients were in institutions.
  4. Eliminate the use of the “R” word is in the regulations.

Section Q Community Referrals

  1. Monitor nursing facility compliance with Section Q referral process and fine facilities that fail to refer consumers for community reintegration who ask for assistance.

IHSS Renewal and Expansion

  1. Revise the definition of “eligible person” to include anyone who is eligible to receive services under any home and community-based services waiver for which HCPF has federal waiver authority.
  2. Renew the program until 2029

Protect Consumer Direction in IHSS

  1. Correct the mis-interpretation of the “Secondary and Contiguous” task rule so that it no longer restricts client ability to direct their own services.
  2. Ensure that clients are able to order tasks in their visit in any manner they choose during each visit to meet their individual needs.
  3. Ensure that providers not train their staff to interrupt a visit to clock-in and clock-out to switch between HMA and personal care visit types when the bulk of the time of a given visit is HMA tasks and the client’s choice is to complete related brief personal care/homemaker level tasks as part of the normal flow of their largely HMA level care during a given visit.
  4. Agree that any guidance and training provided by HCPF to providers/attendants/case managers on what does or does not constitute a “related” and “secondary and contiguous task” must be vetted and approved by ADAPT and the PDPPC.
  5. Work with ADAPT to identify reasonable guidelines to protect consumer direction in IHSS, while ensuring appropriate use of Medicaid dollars.

Non-Medical Transportation

  1. Agree to amend all adult Home and Community Based Services waivers to include non-medical transportation (NMT) through the purchase of a bus pass, or other public conveyance, when it is more cost effective than, or equivalent to, the applicable mileage band (10 CCR 2505-10 8.500.5.A(4).