This is part one of my last blog post of 2018. Read both parts one and two quickly, because decisions are being made in the early days of 2019 by the D.C, Department on Disability Services (DDS) about new policies and procedures affecting anyone who gets residential supports from DDS.
At the December 13 Supporting Families Community of Practice meeting, the revised policies and draft procedures to accompany them (https://drive.google.com/drive/folders/1h6PCyTDF7rPUxgOl5ntF2f0Ws71CvLu8?usp=sharing),
were distributed and discussed in small groups. These are complicated documents, and I’m happy to learn that, contrary to its original plans, DDS is extending the period for feedback at least to mid-January. Both will be reviewed again at HCBS waiver meetings in early January, and at the Project Action! meeting in January.
There’s little that can be done with respect to the Contribution to Costs policy and procedures, since the D.C. council already passed its law and since the regulations have been finalized. This set of documents will, however, be discussed on Wednesday, January 2 at 2:00 in the Joy Evans conference room at DDS headquarters. As I’ve said before, I don’t believe there was sufficient effort to make stakeholders aware when the law was submitted and the regulations were out for comment last year. However, at this point any fundamental changes are going to require further action by the D.C. council. In the near term, as DDS moves to implement this policy, I see two significant considerations:
1) Implementing the contribution to costs policy and procedures is going to involve some very large changes in practice, both at intake and in annual ISP (Individual Support Plan) meetings. Many service coordinators are struggling to accomplish their core functions and will need solid backup to deal with these new complexities, so DDS needs to make sure it develops a team of dedicated staff who will fully understand all the financial implications and calculations. We were told on December 13 that people will receive a detailed accounting of the locally-funded costs of their care, and this will be a complex undertaking. In the longer term, there are surely going to be other unforeseen consequences from the contribution to costs policy for this unit to consider. (I also would like to know what DDS has in store with respect to the language in the policy under 2.A., “or their estates,” which is not addressed in the procedures.)
2) Some foreseeable financial implications will result from changes that would come under the accompanying “HCBS Housing Choices” policy and procedures, which I’ll discuss in part two of this blog post. People’s SSI payments don’t only decline as a result of work income. It’s also the case that if family or others help people with their housing costs over and above what DDS pays, their SSI payments will go down in that case as well. People still will get their $100 allowance, but DDS will receive less.
An urgent change that I hope the council will make immediately is to ensure that cost-of-living increases will apply to the allowances received by the people DDS supports. A fixed $100 allowance year in year out will have the effect of progressively impoverishing D.C. citizens with disabilities as the cost of living increases, while DDS gets the benefit of the annual increases in SSI or other benefits (making the name "Independence Square" in the accompanying photo of DDS headquarters especially ironic.) This is a flawed arrangement, not fair or justifiable, and I look forward to a change by the council very soon to remedy this, preferably by calculating contributions to costs on a percentage, rather than fixed-amount, basis.