ADM #2015-05-R2 regarding IDGS Service Documentation must be withdrawn and corrected!
POSITION STATEMENT - #2015 ADM-05 R2 Draft
Service Documentation for Individual Directed Goods and Services (IDGS)
To support the ability of people with developmental disabilities to access the services that they choose, draft ADM #2015-05-R2 regardingIDGS Service Documentation must be withdrawn and corrected.
The Coalition for Self-Direction (C4SD) provides these comments on behalf of the community of family advocates in New York State. We are a grass-roots organization of parent-volunteers who seek to promote and preserve freedom of choice for all people with developmental disabilities.
We are happy for the opportunity to comment on the draft ADM regarding IDGS, Individual Directed Goods and Services, and the accompanying 17-page form. We can see that there was an attempt to make things better, and the ADM does contain several important improvements. However, there are three critical gaps in the guidance it provides. Consequently, we must call for this ADM to be withdrawn and corrected.
The first problem is that it fails to implement the appropriate due process protections. The second problem is the failure to define a key term that has been broadly misinterpreted in the past four years: “duplicate”. Last, the ADM creates a brand-new gap in guidance. The new ADM and accompanying form have contradictory guidance regarding what criteria must be met by IDGS.
This new gap, and the old ones, push financial risk onto the Self-Direction Fiscal Intermediaries (FIs). These non-profit organizations depend upon OPWDD guidance. When there is a gap in the guidance, the FIs (Fiscal Intermediaries) tend to pick the interpretation which reduces their risk of financial claw back. Medicaid Auditors typically resolve ambiguity by choosing the more restrictive interpretation, and FIs behave rationally in the face of this auditor behavior. The unfortunate result is to turn the FIs into ‘the department of no’.
As drafted, the ADM will perpetuate and worsen unnecessary financial and human costs. Were it implemented without changes, the outcome would be a reduced ability to put together a life of dignity and meaning using Community Classes that are open to the public. With other options cut off, there will be an increase in the demand for segregated Day Habilitation programs. These Day Programs are explicitly closed to the public. This would make it that much harder for people to participate in the broader community life.
This document contains our recommended corrections to this proposed ADM. See the second to last page of this document for our list of specific changes. We believe all of them can be turned around in less than a month. We also supply that same list as a standalone one page document.
Key Concepts
This section presents a handful of inter-related concepts which we believe should inform New York State’s approach to IDGS policy.
Re-Focus on Person Centered Services
We need to start with the goal in mind: Providing the opportunity for people with IDD to pursue a meaningful life. As laid out in the 2016 document published by the grassroots New York Self-Determination Coalition, self-directed services are “designed for, and based on, the individual’s interests, goals and needs.” “Because of this highly responsive, customized system of supports, people have the chance to develop rich multilayered relationships and spend their time doing activities that absorb them”
Ever since the launch of the Self-Direction program in New York State 25 years ago, there has been an on-going tension between two goals:
· maximize individualized choice in services, and
· maximize Federal participation in payment for services.
There is nothing inherently wrong with that second goal—we support having Federal Medicaid pay for half the costs of some services, provided we retain a full range of services which people can use to spend their lives “doing activities that absorb them”.
The tension turns into conflict when the pursuit of Federal participation results in cutting off access to important services. That is when the disagreements between OPWDD and the community they serve becomes especially bad—when New York State policy narrows the options available to people. NYS pursues a low-risk pathway, and pushes the ‘cost’ of that onto people with IDD.
Embrace Universal Design
Universal Design is a concept that grew out of architecture. The concept is easy to express: We should design products and environments to be usable by all people. To be ‘universally accessible’. The corollary is that design for universal access often provides unexpected benefits to the larger society.
Curb cuts are the classic example of Universal Design. Curb cuts make it easier for someone in a wheelchair to travel around a neighborhood. And those same curb cuts are available to everyone, bringing benefits not only to wheel-chair users, but also to parents with strollers and FedEx workers with hand-trucks.
Universal Design started with architects and city planners. It has long since spread to other domains, including education. A framework called Universal Design for Learning (UDL) calls for classes to be designed so that all learners can engage in meaningful learning.
Looking through the lens of UDL at the world of Community Classes in New York State for people with IDD, we should embrace classes that are ‘curb cuts’—designed to meet the needs of people with IDD, but open for everyone and anyone to utilize.
Material on Universal Design:
https://design.ncsu.edu/research/center-for-universal-design/
Informed Choice
In the draft ADM on Housing Subsidy that was issued in August, #2026-02, OPWDD introduced the concept of documenting informed choice. Specially, that ADM called for allowing the person with IDD to make the choice to live with other people who also have disabilities.
This same idea of informed choice should be applied to the choice to attend a ‘universal design’ community class—one that is tuned to the needs of people with developmental disabilities and that is available to all.
Allowing this would permit Fiscal Intermediaries to focus on the needs of people with developmental disabilities, rather than focusing on the needs of the NYS Office of Medicaid Inspector General.
Desire Paths
In 2018, a reform in OPWDD’s Community Class guidance created something akin to a free market for Community Classes. Suddenly, thousands of adults with IDD had a budget that they could spend on the classes that they selected. In response to this new market, Family members and other community members created a variety of Community Classes in alignment with the principles of Universal Design: Open to the public and accessible by people with IDD. Freedom of choice flourished for a few years, and people with developmental disabilities were better able to pursue their interests and ‘live richer lives.’
If we are to achieve a truly sustainable system of care, policy must support the work of these innovators, not prohibit it. Early in 2026, OPWDD leadership spoke about the concept of ‘desire paths’—find out where the people want to walk, and then pave those routes. This is a beautiful concept.
What OPWDD has done is the opposite: The community has used their budgets to express their desires, and this ADM as currently written creates barriers to prevent the fulfillment of those wishes,
Improvements We Noticed in the Draft ADM
The draft ADM does contain several improvements.
And, we are adamantly opposed to implementing this current draft, because it creates problems that make things even worse than our current situation. These problems are easy to fix. We summarize the suggested changes in the final two pages of this document. People with IDD should not have to go wait another 4 years for the required improvements. (The last change to this ADM was in May 2022, more than four years ago).
1. Dispute resolution and review. The ADM defines a process to challenge decisions at the Fiscal Intermediary (‘dispute resolution’), and a path for escalation to OPWDD (‘administrative review’). This will provide a consistent approach, with designated response times. Unfortunately, the ADM fails to describe the due process rights of individuals who want to challenge the decision. See problem #1 below, Lack of Due Process. A much more minor problem is that while the ADM specifies each time period leading up to the Administrative Review by OPWDD, it does not provide a target for completion of that Administrative Review.
2. Defined decision criteria. The ADM is accompanied by a form which will serve to enforce several long over-due positive changes. Start with, the reason for a denial will always be in writing. The decision will be accompanied by the contact info for IDDO, the Independent Developmental Disability Ombuds. Unfortunately, the form does not inform every one of their right to a Medicaid Fair Hearing. See problem #1, Lack of Due Process. Further, the ADM fails to define a vitally important term. Problem #2, Defining Duplicative. Last, the ADM and the form contain contradictory guidance, which will worsen the confusion and conflict in the field. Problem #3, Other Gaps in Guidance.
3. Mandates help with paperwork. The ADM specifies that the Support Broker and Care Manager have an obligation to assist with the new IDGS form. And even better, the Fiscal Intermediary has an obligation to convert to writing any verbal request it receives for either Dispute Resolution or Administrative Review. “If the person or their representative needs help completing the appropriate OPWDD-approved form, their Support Broker or Care Manager must help them.” “If a [Dispute Resolution] meeting is requested verbally within 30 days but the appropriate OPWDD-approved form is not completed, the FI must complete it on the person's behalf based on information provided.” “If Administrative Review is requested verbally within thirty (30) days of the Dispute Resolution denial … the FI must complete it on the person's behalf based on information provided.”
Problems With the IDGS draft ADM #2015-05-R2
In Summary
The IDGS ADM has three major failings. We call upon OPWDD to withdraw this ADM, make revisions, and repost for public comment. We list all suggested revisions on the second to last page of this document. We believe all of them could be easily implemented in four to six weeks.
The first problem with the IDGS ADM is that it fails to address the need for due process. Specifically, it does not mandate that participants receive a Notice of Decision informing them of their right to a Fair Hearing for every IDGS decision. The ADM does define an ‘administrative review’ process that is internal to OPWDD, which is good, but does not adequately preserve the right to an impartial review. People with Developmental Disabilities must have the ability to appeal to an independent Hearing Officer when they disagree with decisions made by OPWDD or by the FIs that work as the agents of OPWDD. They must get a Notice of Decision informing them of those rights, just as is routinely issued when there is a decision about other OPWDD services such as CommHab, DayHab, Supported Employment. A decision on a specific IDGS will have a similar impact on quality of life, and the person impacted must have the opportunity to make their case to a neutral party.
Second, it fails to clarify what is meant by ‘duplicate’. This has been a major problem for the past four years, which the advocacy community has consistently brought to the attention of OPWDD. In the absence of clarity, FIs will maximize their caution, to make it less likely that they suffer financial claw back when the auditors come to visit. In contrast, if OPWDD provides clarity, then FIs will be empowered to maximize their focus on meeting the needs of the individual. For duplicative, CMS has a very specific, technical interpretation, embedded in their 365-page technical guidance document. That guidance includes specification of what allows two similar things to NOT be duplicative: Different time periods, different frequency, different vendors-- any of these can make it clear that two similar things are not duplicative of each other. See CMS publication 1915c Technical Guidance, pages 127-130. To fulfill their mission of helping people with IDD achieve lives filled with meaning and dignity, OPWDD has an affirmative responsibility to provide clarity to the Fiscal Intermediaries. The current version of ADM and the accompanying form do not provide that.
The third major problem with this ADM as written is that it creates a brand-new confusion regarding allowable community classes. It appears from a strict reading of the ADM that they are only approvable if they result in either "increased independence" or "reduce the need for staff assistance". This means it will no longer be permissible to take a class because you are interested in the topic. This provision stands in direct contradiction with the definition of a community class as one that is "in any subject area that relates to a person’s valued outcomes". And it might also contradict the new ADM form, which seems to allow a broader range of classes to be approvable.
If this ADM is released without changes, then Fiscal Intermediaries will likely deny reimbursement unless the class reduces costs (staff assistance) nor increases independence. We hope that this was the unintended result of an over-enthusiastic use of the word ‘must’.
If it was the intention, it is bad policy which will reduce access to classes and diminish quality of life.
Problem #1: Due Process
The ADM defines a standardized process when there is a disagreement about an IDGS decision—'dispute resolution’ at the FI and then ‘administrative review’ by OPWDD. This is a big step forward, and we celebrate it.
However, the ADM fails to mandate that every IDGS decision must be accompanied by a Notice of Decision informing the participant of their due process rights. This would be easy to implement—the Notice of Decision could simply be added to the end the 17-page IDGS decision form, along with language instructing people to turn to page 18 to learn about their right to a Medicaid Fair Hearing.
We hope that the use of Medicaid Fair Hearings will be rare—that most decisions will be based on good policy, focusing on the needs of the person with IDD. And that the internal OPWDD ‘administrative review’ will reverse FI decisions that are incorrect. That is our hope.
However, we recognize that systems do not always behave as well as we wish they would. In the future, OPWDD might be pressured to reduce overall spending—or pressured to reduce the risk that a hostile Federal administration will find specific spending that they will disapprove of. Fiscal Intermediaries could then be pressured to approve fewer classes. If that cascade of events should happen, then OPWDD review of the FI decision will not result in a just and impartial outcome.
In contrast with the OPWDD ‘administrative review’ described in the ADM, Medicaid Fair Hearings:
1. Are conducted by a semi-independent State Agency, the Office of Temporary and Disability Assistance (OTDA).
2. Produce a public record of the decision. The decision archive is freely available to anyone with an internet connection: otda.ny.gov/hearings/search
3. Allow the individual to demand continuation of aid when disputing a discontinued service.
Moral obligation to provide a Notice of Decision
For these three reasons, we believe that OPWDD has a moral obligation to provide a Notice of Decision (NoD) for every single IDGS decision. This will be very simple for OPWDD to implement, by adding the standard language of a NoD to the file used to track the IDGS request and decision.
The draft ADM does call for a Notice of Decision to be sent out, but only in a situation which is exceedingly rare: When the IDGS is denied because there is not a documented Valued Outcome in the Life Plan, and then the individual refuses to update their LifePlan. That is the only circumstances under which the ADM mentions a Notice of Decision. Our educated guess is that with tens of thousands of IDGS decisions each year impacting tens of thousands of people, this circumstance occurs almost never. Probably less than ten times in a year.
A legal obligation to issue a Notice of Decision
Alongside of the moral obligation, OPWDD has a legal obligation to provide a Notice of Decision informing people of their right to a Medicaid Fair Hearing. We know OPWDD’s legal department does not agree that they have such an obligation--OPWDD attorneys have repeatedly argued that IDGS decisions are not reviewable. They have made this argument in multiple Medicaid Fair Hearings, and in multiple Article 78 cases in NYS court rooms.
However, we have reviewed the publicly available records and have found three Article 78 cases that have been held over the last two years. In each instance the New York State Judiciary has stated that OPWDD’s position on the right to notice and fair hearing is not valid.
· Index 610162/2023. Final disposition Dec 12, 2024. Judgement issued by Hon. George. Nolan “it appears that OPWDD deprived the petitioners of their right to notice, and a fair hearing as required when an agency discontinues, suspends or reduces a Medicaid recipient's benefits or services”
Same index. Motion for Attorney's fees. May 27, 2025. Judgement issued by Hon. George. Nolan “OPWDD's actions and its determination denying reimbursement for the class attended by
[plaintiff first name redacted] were not substantially justified as it lacked a reasonable basis in both law and fact. As the court noted in its decision and Order of December 12, 2024, it appears OPWDD denied the petitioners their right to notice and a fair hearing to contest OPWDD's determination. In fact, both before and after this proceeding was commenced, OPWDD took the untenable position that [plaintiff last name redacted] had no right to challenge OPWDD's determination, not even through an Article 78 proceeding. Further, the facts and evidence justifying OPWOD's determination were scant, nearly non-existent.”
https://iapps.courts.state.ny.us/nyscef/DocumentList?docketId=08/qB1MddBA5PsjSMEewVg==&di splay=all&courtType=Suffolk%20County%20Supreme%20Court&resultsPageNum=1
· Index 2024/ 04229. Judgement issued January 9, 2025 by The Supreme Court of New York, Appellate Division, First Department.
“We note that petitioner is indeed entitled to a fair hearing before DOH to determine whether the withdrawal of funding approval for the community classes in question was improper …. and any other issue they deem proper. The record on appeal demonstrates that DOH agrees”
https://iapps.courts.state.ny.us/nyscef/DocumentList?docketId=HMPQ5Q0yw9nyziGPkc_PLUS_/zA
==&display=all&courtType=Appellate%20Division%20-%201st%20Dept&resultsPageNum=1
· Index 507721/2026. September 21, 2026. Judgement issued by Hon. Anne Bianchi. "the Court concludes that … the Petitioners were deprived of their right to notice and a Fair Hearing as required when an agency discontinues, suspends or reduces a Medicaid recipient's benefits or services, and that such final administrative agency determination without notice and a Fair Hearing by DOH, OPWDD and AIM is arbitrary and capricious and lacking in a rational basis." https://iapps.courts.state.ny.us/nyscef/DocumentList?docketId=wQYj5vufmQV19voDkAvh7A==&di splay=all&courtType=Westchester%20County%20Supreme%20Court&resultsPageNum=1
Problem #2: Defining Duplicate
The Self-Direction Assessment executed by Guidehouse for OPWDD highlighted the need for “clearer guidance” on Community Classes. This revision of the ADM and the accompanying form do not address this self-identified problem.
OPWDD has an affirmative responsibility to offer similarly detailed guidance to the Fiscal Intermediaries and to the people they serve. In the absence of such guidance, the suffering on all sides will continue. As detailed in the Guidehouse report:
“OPWDD mentioned the overwhelming amount of time and administrative burden that goes into oversight of this item in the IDGS service…. FIs must approve or deny requests for community classes based on their understanding of OPWDD and federal guidelines. This has resulted in inconsistent access to community classes, which contributes to dissatisfaction among those self-directing.” Page 81 Self-Direction Assessment Final Report
Duplicate Left Undefined
While there are multiple definitions of other terms in the ADM, “duplicate” is not defined. In fact, the word does not even appear in the ADM. The word shows up in the accompanying 17-page form as a reason to deny services. One of the grounds for denial is if the requested community class:
“Duplicates service available through HCBS Waiver, Medicaid State Plan, or another public program”.
In the absence of any definition from OPWDD, Fiscal Intermediaries will tend to be very restrictive in what they approve, due to the fear of financial claw back from the NYS Office of the Medicaid Inspector General or other auditors. OPWDD’s failure to define ‘duplicate’ has prevented people from gaining access to a more integrated life.
To provide clarity, OPWDD could copy/paste language from CMS. In their technical documentation, CMS explains what duplicate is not, and what characteristics allow us to distinguish among things that appear similar to each other. CMS has already written a first draft of the criteria on page 130: Services are not duplicative when "the scope of the … coverage is materially different”, "the providers of the waiver service are different", or "the method of service delivery is different".
The guidance from the Federal authority tells us that duplicate is a concept that is distinct from resembling, or overlapping, or being able to substitute for. Without clarity on this specific point from OPWDD, the unnecessary denials of important services will continue, the disputes and inconsistency and dissatisfaction will continue.
One easy way to make a service non-duplicative is to have different providers. When NY Community Classes are compared to other waiver services, non-duplication is guaranteed by the provision which excludes classes "conducted by an entity that delivers" Medicaid State Plan or HCBS Waiver services. The clause forbidding 'duplicate … services' is redundant.
Before the IDGS form is released, the term ‘duplicate’ must either be defined, or removed.
Details of CMS Definition of Duplicate
The CMS technical guidance documentation clearly tells us what duplicate does not mean.
a. Substitution. The ability to substitute for another service is part of the core definition for IDGS. Since substitution is allowable, it cannot be the same thing as duplication which is not allowed.
b. Overlap. They provide an example of overlapping service definitions. The guidance does make it explicitly clear that "similar functions" are allowed. Therefore, similarity is not the same as duplication.
c. Similar. CMS explains how to design a waiver service so that it does not duplicate a State Plan service despite being similar. Vary the amount, duration, frequency, providers, method.
Substitution is allowable: Decrease the need for other services
Regarding IDGS (Individual Directed Goods and Services), the CMS Technical Guide states that to qualify for Medicaid funding, the goods and services must meet one or more of three possible requirements. The first of those is the ability to substitute for another service. Their wording:
· "the item or service would decrease the need for other Medicaid services". (Core Service Definition on page 184 of 1915c Technical Guidance). https://wms-mmdl.cms.gov/WMS/help/35/Instructions_TechnicalGuide_V3.6.pdf
Logically, something that is explicitly allowed cannot also be forbidden. New York State cannot decide that a service duplicates other Medicaid services just because it decreases the need for those services. Therefore, duplicate is not: Another waiver service could also satisfy the same need.
Overlap is allowable: Similar functions, just not duplicate billing
The CMS Technical Guide provides a concrete example of what is NOT duplication, citing the considerable overlap in what is done for case management and for support brokerage. The clear message: Similarity and overlap are allowable. Duplicate billing is not. Emphasis added in passage below.
"For example, when a participant is directing waiver services, the participant may be concurrently receiving both case management and … support brokerage…. both services may entail performing similar functions (e.g., assisting the participant to locate service providers). CMS does not require that service definitions be fashioned to eliminate all potential overlap (e.g., by only permitting support brokers or case managers to provide assistance in locating providers but not both). However, service definitions should be structured so that they prevent the duplicative performance of and billing for the same activity undertaken on behalf of a waiver participant by multiple providers." (pages 128-9)
This passage makes it clear: Overlap and similarity are perfectly fine. The thing that is not allowable: Duplicate billing.
Non-duplicate: Vary amount, duration, frequency, providers, method
The CMS Technical Guide also explains how to differentiate between services which might otherwise be viewed as duplicate. Things that appear similar can in fact be non-duplicative if they vary in any one of five ways.
1. Different amount
2. Different duration
3. Different frequency
4. Different providers
5. Availability of participant direction
This appears in the explanation of the requirement that Waiver services cannot duplicate State Plan services. Emphasis added in passages below.
· "Waiver services may not duplicate the services that are provided under the state plan, but a waiver may expand upon the amount, duration, and frequency of services provided under the state plan…" (page 127)
· "When a service coverage is proposed that appears to duplicate a state plan coverage, CMS will probe more deeply to determine whether the proposed waiver coverage is sufficiently distinct from the state plan coverage to warrant approval. The coverage generally will be considered distinct when: (a) the scope of the waiver coverage is materially different from the state plan service (b) the providers of the waiver service are different from the providers of the state plan service; and/or, (c) the method of service delivery is different (this difference may entail the availability of participant direction options under the waiver which are not available under the state plan)." (page 130)
Problem #3: Creating New Ambiguity
According to the ADM itself, reimbursement now requires that a class must "support increased independence or reduce the need for staff assistance." Read strictly, you may no longer take a class because the subject interests you, or helps you be a participant in your community. The ‘must’ seems contrary to the accompanying form. In the form, Part B Step 3A, a class can be denied if it “Does not support independence, community integration, or health and safety”.
Given the ‘or’, a class can be approved if it promotes any one of these three things—and therefore it does NOT need to support independence. There is no denial reason due to a failure to reduce the need for staff assistance. There is however an earlier section of the form, Part B Step 1, where there are eight criteria which can be checked. Here we have similar language to the list in the ADM. The instructions are not clear—will a class be denied if it does not meet all eight of the criteria in Step 1?
The problem is that our service delivery system is patrolled by auditors who will claw back money if there is a mismatch between provider behavior and any part of the guidance. When there is contradictory guidance, the Fiscal Intermediaries are motivated to follow the most restrictive one—in this case, that most restrictive statement is the one in the ADM.
“To be reimbursed, IDGS must:
… Support increased independence or reduce the need for staff assistance”
That ‘must’ contradicts the ADM's own definition of a community class as one "in any subject area that relates to a person's valued outcomes." Both the definition and the “must” are new in this revision of the draft ADM. People with a savvy parent or broker will find words that satisfy the test. They will connect the dots between the concept of independence and a class that makes someone happy. Greater happiness means fewer behavioral outbursts which then allows greater independence. Other people will be left out, especially those with less education or less leisure time. This ambiguity will be yet another barrier to access, yet another cause of inequity.
In Closing:
C4SD’s List of Recommended Changes
The first three are vital, and are also easy to implement. The remaining items are minor improvements, and even easier.
1. Due process. Add the Notice of Decision (NoD) of the right to a Medicaid Fair Hearing to the end of what is currently a 17-page form. The standard NoD for SNAP benefits or Medicaid renewal is 3 pages. Refer the participant to that NoD at various appropriate places within the form. The NoD will of course specify the filing requirements for a Fair Hearing, including the abbreviated time available to request ‘aid to continue’ when an existing class is discontinued.
2. Duplicate. Either eliminate ‘duplicates’ as a reason for denial, or provide a detailed explanation of what it means to be duplicative. That explanation should be based on the CMS technical guidance document, and include a clear distinction between on the one hand the prohibited ‘duplicate’; and on the other hand, the allowable similar, overlapping, can substitute for.
3. Contradictory guidance. Clear up the new contradiction between the requirements of the ADM and the form. The form might allow approval of classes that neither reduce need for staff nor make the individual more independent. The ADM appears to require that a class must achieve one of those two goals to be approved—which is bad policy. We recommend eliminating this criteria. And in the long term, change the language in the next version of the HCBS waiver. Alternatively, level the playing field by adding explanation to the form that allows anyone to connect the dots between a satisfying experience and ‘independence’. This could be done with just a couple of sentences, such as “A class that provides the individual with a positive experience or emotional satisfaction will meet the criteria of supporting independence. A happier person is less likely to have behavioral outbursts, thus less likely to require interventions, and more likely to be integrated into their community.”
4. Minor: Specify a timeline for OPWDD to complete Administrative Review.
5. Minor: Form improvements. Create a first page which summarizes the current status of the request for IDGS approval. A series of steps, each with a date field—submitted, decided with a notation of approved or denied. FI Dispute Resolution, if requested, with each of the specified time periods for substages, and the outcome. OPWDD Administrative Review, with date of submission and a specification of the due date. An optional field for Medicaid Fair Hearing request, with a notation that this can be requested in parallel with the Dispute Resolution and Administrative Review processes, but that the request must be submitted to OTDA within XX days of the initial denial.
6. Minor: Differentiate a review from an initial request for approval. The IDGS approval process as currently defined calls for a new form to be submitted when an FI wishes to review a previously approved class. Add checkboxes on the tracker sheet at the front of the form, to specify whether this is a new request or the review of one previously requested. This differentiation is important because the right of ‘aid to continue’ is only available when a previously approved service is discontinued.
Final Words
We urge OPWDD to revise draft ADM-2015-05 R2 consistent with our recommendations listed above and repost for public comment prior to issuance. We call on OPWDD to engage family members, self-advocates, providers, and the IDDO in the revision of the ADM. This will greatly enhance the possibility that we create and sustain a system of services that achieve the OPWDD mission and vision
The Mission...
We help people with developmental disabilities live richer lives.
The Vision Statement…
People with developmental disabilities enjoy meaningful relationships with friends, family and others in their lives, experience personal health and growth and live in the home of their choice and fully participate in their communities.
Thank you for your consideration and for your support of people with developmental disabilities. We are available to provide additional detail and clarification, and to participate in the process of making the required corrections.
Sincerely,
Jim Karpe
Father of two adults with I/DD
On Behalf of The Board of The Coalition for Self-Direction:
Heather Burroughs, Stacey Cagan, Jackie Ceonzo, Jim Karpe, Susana Montes, Chris Palega, Molly Sebastian
