Category: VCDR Commentary
VCDR weighs in on issues affecting the VCDR community
Comments on the Proposed 2018-2020 System of Care Plan
September 15, 2017
Clare McFadden VT Department of Disabilities,
Aging and Independent Living Developmental Disabilities Services
Division 280 State Street Waterbury,
Vermont RE: Comments on the Proposed 2018-2020 System of Care Plan
Dear Clare, Thank you for the opportunity to comment on the proposed Vermont System of Care Plan. I’m writing on behalf of the Vermont Coalition for Disability Rights (VCDR) which is a membership organization working to increase awareness of disability issues. We support the comments presented by VCDR members and allies including Green Mountain Self Advocates, Vermont Family Network, Vermont Developmental Disabilities Council, Vermont Legal Aid and Susan Yuan.
Page 10:The full intake process needs to be completed for every applicant and the plan should require DA’s to inform applicants of any delays in the screening process and be transparent with an anticipated timeline.
Page 11: Information and options must be presented in an unbiased prevention. This could be done through peer supports. GMSA, VFN and VCIL have worked with the Aging and Disability Resource Connection, in the past and have spent significant time focused on options counseling which allows for information to be presented by an organization or program that does not have a stake in the information being presented.
Page 14: Would be good if this is a stand alone section so it is more clear. Time limit for the assessment and the appeals right need to be clear and more accessible.
Page 17: Emphasis on conflict-free case management. This can be done by someone other than the DA. VCDR members have a lot to offer through peer support and option counseling. GMSA is willing to help the state make a plan for this work.
Page 19: What group homes would be approved. (Check this out…only VLA)
Page 20: People should be able to choose to participate in community activities how they wish and there should be less reliance on day program activities for those who choose. This should be connected to compliance with the HCBS rules.
Page 25/26: Clarification needed on who may request funding from the Developmental Disabilities Specialized Service Fund and request for Employment Conversion.
Page 28: Flexible Family Funding – see partner organizations “major concerns” for the inadequacy of the flexible family funding. In addition to the increase that is needed, we support GMSA’s proposal that flexible funding should be available to an individual who is eligible for services but who does not meet a funding priority.
Page 35: Language/Rules for distributing One Time Funding need to be more transparent around how funds are being spent. Funds need to remain in Developmental Disability Services.
Page 37: Agree that One Time Funding should include staffing support costs for training/conference
Page 42-43: Would like to see peer-to-peer mentoring projects to the Special Initiatives List.
Page 45: Concerns with the majority of members submitting comments that the presence of natural supports cannot be used as a reason for not providing services. It is imperative that plans do not rely too much on natural supports and make families feel as if they need to provide those services. The availability of natural supports should not be a factor when determining service needs.
Page 51-52: Respite needs should be flexible and based on need. Appeal rights need to be included for better implementation through the DA’s.
Page 54- The cost to deliver services is often higher than the rate set by DAIL. The rate of the individuals budget should be set at the actual cost and not less.
Page 55: Removal of consumer choice from the process and moved to the DA which is problematic. Bidding process should be eliminated.
Page 60: Some services listed are clinical and cannot be limited as they are in the State’s Medicaid Plan.
Page 61: Cap is too low and the maximum rate does not meet the current workload demand.
Page 63: There must not be a waiting list for EPSDT services. There should be language added that make it clear children will not be put on a wait list including targeted case management. If there is a waiting list, the data collected must be shared with the public.
Vermont Coalition for Disability Rights
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