CALL TO ACTION- Public Comment ends December 28 at 4:30pm!
The Division of Disability and Rehabilitative Services (DDRS) has put together an amendment regarding the Community Integration and Habilitation (CIH) Waiver. This waiver is how thousands of people receive Music Therapy in the State of Indiana if they have an intellectual or developmental disability. This amendment suggests that if someone is receiving residential services, they would no longer be able to bill Music Therapy due to the new daily rate and a new ban of concurrent services. In addition, people would no longer be able to use waiver funds for transportation services if they are being transported to another waiver funded service such as Music Therapy. Finally, this would also eliminate the “buckets” of waiver funds which reserve a person’s funds for DAYS services, of which Music Therapy is a part. This will likely take Music Therapy out of the conversation when choosing services as the case manager would no longer be required to choose a certain amount of DAYS services to place on the plan before entering residential services.
These changes can be seen at http://www.in.gov/fssa/ddrs/4205.htm
Please use the suggested language below in an email to CIHW@fssa.in.gov before the deadline of December 24 at 5pm, as these changes could drastically reduce those receiving Music Therapy in Indiana! Please don’t forget to insert your name. You can send questions regarding this proposed amendment to firstname.lastname@example.org.
CIH Amendment Public Comment
c/o Division of Disability and Rehabilitative Services
402 W. Washington St., #W453
P.O. Box 7083, MS26
Indianapolis, IN 46207-7083
COMMENT RE: Application for 1915(c) HCBS Waiver: Draft IN.006.03.02 – Oct 01, 2016
Thank you for the opportunity to comment on the proposed amendment to the Community Integration and Habilitation Waiver. I greatly appreciate that my feedback might aid in the construction of these waiver guidelines.
I am a music therapist working in Indiana and am concerned that this amendment might have a negative impact on those receiving our services. The new services including “Enhanced Residential Living”, “Intensive Residential Supports-Medical”, and “Intensive Residential Supports-Behavioral” prohibit concurrent services. This implies that a person receiving waiver services would need to choose either residential services or activities/ therapies such as Music Therapy, Recreational Therapy, Behavioral Management, or DAYS services. This does not at all address the needs of many of those receiving waiver services. I feel that this would force most people to choose health and safety over quality of life, which would most certainly limit people’s ability to be contributing members of their communities and place them in a more institution-like living situation.
I am also concerned that the changes to the transportation service will keep people from being able to attend appointments or work in the community. This change in the service implies that you can only have therapy if you are able to drive yourself or have significant natural supports, excluding those of fewer means who may be in most need of therapy.
Finally, I fear eliminating “buckets” for DAYS services and BMAN services might have a negative effect on those receiving waiver services. First, this change might lower a person’s community involvement and thus quality of life. The current system encourages community involvement and skill acquisition especially for those without self-advocacy skills. This might unfairly distribute therapies and DAYS services to those who can more easily communicate, leaving those out who don’t have the ability to advocate for themselves. Secondly, this might encourage people to jump from one service to another more frequently. We know that rapport building takes time and shorter relationships with service providers will likely reduce people’s achieved outcomes while utilizing these services.
Thank you for considering these revisions to the proposed Home and Community Based Services Waiver draft. I appreciate Indiana Family and Social Services Administration (FSSA) and the Division of Disability and Rehabilitative Services (DDRS)’s commitment to improving the lives of people with developmental and intellectual disabilities.