Welcome to C4SD’s Administrative Directive Memorandum (ADM) Hub!
We’re pushing back against a series of OPWDD’s proposed rule changes (ADMs) that will devestate our Self-Direction Community. We must stop these mis-guided and unnecessary policies in their tracks, and replace them with resonable and effective real world solutions!
We started this work by making it easy for everyone in our Community to reach out to OPWDD to share their public comments! We created Position Statements to educate and empower, and the simple tools needed to mold our voices into one!
We drove over 600 public comment emails from the C4SD Community directly into OPWDD's Inbox! That’s an incredible show of strength through solidarity, and a reminder to OPWDD of the impact we can have when we all work together to achieve our common goals!
This is just the first important step in our campaign to stop these mis-guided and unnecessary policy proposals in their tracks
Changes to Contemporaneous Billing Requirements for Self-Direction Brokers
#2026-ADM-01 Draft Contemporaneous
New rules under public review will require support brokers to complete and upload all service notes and billing within 2 business days of providing those services! There’s no exceptions, no grace period for anything that comes up, even if a support broker or someone they care for has a health crisis or other emergency!
Hard working, dedicated independent support brokers across the State are telling us that these unreasonable administrative burdens will force them to reduce caseloads. Some are already considering leaving the field, while others will hesitate to enter. How will you manage your budget without guidance and coordination from a support broker? How will you find a new broker if you’re dropped by yours? How will the system make up for what looks to become a dramatic loss of support brokerage services? Among the changes we are fighting for:
OPWDD needs to understand that Support Broker records are already subject to highly effective oversight, monthly review, and approval.
OPWDD can require Support Brokers to upload their time records at the end of each month, or within a workable time frame, with their signed attestation that all records were created contemporaneously.
OPWDD must distinguish between shift-based Direct Services like CommHab, and Support Brokerage Services which are Coordination Services provided for many different clients every day!
Tap or Click Here For Our Detailed Policy Position & Recommendations!
Changes to OPWDD’s Housing Subsidy Requirements
##2026-ADM-02 Draft OPWDD Housing Subsidy
Our Coalition was heartened by OPWDD’s stated purpose for this ADM, that the “overarching premise of this Housing Subsidy program is to give people the ability to make their own choices and set their own goals when choosing where to live.”
Unfortunately, the current draft ADM simply does not deliver. While we celebrate the handful of improvements, this proposal will reduce options and eliminate choices. The draft effectively eliminates use of the subsidy for Provider Managed Housing, and explicitly prohibiting use of the housing subsidy by people who choose to live in campus-like settings. The proposal denies a housing subsidy to people who need 24/7 support, leaving them with few options despite detailing the self-determination rights of “all people, including those with developmental disabilities”.
We believe that opportunities to live in the community should include campus settings, provider managed housing, and more. Unfortunately, the draft ADM does not support these options! Among the changes we are fighting for:
OPWDD must expand the opportunity to live in these settings when supported by the renter’s statement that they understand and freely choose the living arrangement they’re requesting to have subsidized.
The draft’s failure to address routine delays in the initial subsidy payment creates an inequitable barrier to access. Many people simply can’t afford to pay rent for several months while waiting for an initial subsidy payment. OPWDD must implement a “provisional approval to pay” approach which empowers Fiscal Intermediaries to begin funding the subsidy upon presentation of a signed lease.
The policy explicitly excludes people with 24/7 support needs. This leaves many who would choose to live in a community setting with support with only more costly certified options. OPWDD must develop a strategy that allows funding to follow the person. We believe that if someone can live by choice in the community at a cost equal to or less than that of a certified setting, we should protect their right to do so.
We’ll be hosting Town Hall discussions on Wednesday, September 16th at noon and -7:00 PM to continue to rally support around this critical issue.
Tap or Click Here For Our Detailed Policy Position & Recommendations!
Changes to How IDGS Servces Are Documented
#ADM #2015-05R2 IDGS Service Documentation
We are calling on OPWDD to withdraw ADM #2015-05R2 IDGS Service Documentation and make corrections to increase transparency and reduce this proposal’s systemic barrier to true self-determination and choice!.
The proposal requires Fiscal Intermediaries to certify that a request "does not duplicate Medicaid State Plan, HCBS Waiver, or other public funding". The proposal also names duplication as a reason to deny services in 4 different places. Unfortunately, the ADM fails to define duplicative. Without a concrete, measurable definition, FIs are disposed to being overly cautious in denying self-directed services out of fear of audits and clawbacks. A clear, measurable definition of duplicative will support the important work of FI’s across the State.
The proposal also creates a unreasonable and unnecessary barriers to community class participation, and it fails to support and require due process for people who have been wrongfully denied access to services!
Tap or Click Here For Our Detailed Policy Position & Recommendations!
Changes to How Fiscal Intermediaries Document Services
ADM #2019-07R FI Service Documentation
We are truly disheartened by the release of 2019 ADM-07R Draft Service Documentation for Fiscal Intermediary (FI) Services. This was the 4th major proposed policy change (ADM) issued by OPWDD in the month of August. OPWDD has already had over 2 years to address deficiencies in this policy after initially withdrawing it in the Spring 2024 following overwhelming negative public comment.
OPWDD has not provided anywhere near adequate time for our community study, review, and comment on 61 pages of text — 44 pages in 4 ADMs plus a 17 page form! Especially when all of these high-stakes documents have a Reading-Ease Score of either “Difficult to Read” or “Very Difficult to Read”.
It is impossible to interpret this behavior pattern as a sincere attempt by OPWDD to engage with the public. We simply do not have the time to adequately understand, analyze, and comment on this proposal. OPWDD should extend the comment period by another 30 days, to the end of October.
Tap or Click Here For Our Detailed Policy Position & Recommendations!
We’ve organized OPWDD’s ADMs and our detailed Position Statements Below. Click through for a deep dive into these policies and check back for updates!