PART TWO: TennCare drops the requirement for Independent Living Centers to have a Day Services License
EDITOR’S NOTE: This is part two about advocate’s work to provide
ECF Services in Tennessee. Please read PART ONE: Tennessee begins a stateprogram that leaves out the state’s Centers for Independent Living.
MCIL was approved by the two Managed Care Organizations to provide
some ECF services, but the Center was informed that the Day Services License
was essential to provide IL Skills Training. Since the ECF program began in
July of 2016, no one was really clear on why the requirement existed. The MCO
representatives agreed that IL Skills by regulation could not be provided in a
facility.
The Day Habilitation license also has requirements on the staff
who provide the services; however, the ECF requirements are more stringent. The
Day Services requirement mandates at least one staff member is available for
every six clients, while ECF is essentially a one-on-one skills training.
Background and registry checks are also required by ECF so there is no material
part of the Day Habilitation license that would be relevant.
“The odd requirement to be a ‘Licensed
Day Habilitation Provider’ seems in contrast to the stated goals of the ECF
CHOICES program and has no benefit for the state or individuals that may use
the program,” MCIL said in a February letter to Dr. Wendy Long, the Director of
TennCare. “Most importantly, please note that providing Independent Living
Skills training according to the ECF CHOICES Guidelines would prohibit any
provider from using a facility or adult day care center because the services
are to be delivered in the community, in the least restrictive setting and in
the individual’s home and community.”
On April 21, 2017 the state essentially changed the requirement.
In a letter to the Program Director of MCIL, Patti Killingsworth, the Assistant
Commissioner and Chief of Long Term Services and Supports wrote that the
provider qualifications would be adjusted.
“A Center for Independent Living,” said
Ms. Killingsworth in the April 21st letter, “as defined in federal law, that is
receiving federal funding from [the] federal Department of HHS to operate as a
Center for Independent Living is qualified to provide services in the
Employment and Community First CHOICES program that would otherwise require an
Adult Habilitation Day Facilities license.”
The state carved out an exemption for CILs, they did not get rid of the unnecessary requirement. The ECF services are to focus on individual integration and independence, the adult day services concentrate on safety. This is the contrast that MCIL noted in the letter to TennCare Director Wendy Long, the state grants approval for a program that has a license, even though the license has nothing to do with the services offered.
Nearly a year after the program rolls out, MCIL may offer
Independent Living Skills training. However, the Center and other CILs in
Tennessee cannot have a good feeling about the long-term viability of the
program. Most importantly is how long it took to have the state recognize the
problem with the day services license. For a year MCO’s and TennCare recognized
the problem; facility license for non-facility services, and failed to act.
In my dealing with MCOs, they listened politely to our case, but
simply agreed that the requirement did not make sense. Reason did not climb the
ladder to action. For most CILs and small providers in the state, the unreasonable
requirement to have a Day Habilitation license seems to be just another
bureaucratic hurtle that made the overall program not worthwhile.
MCIL may provide IL Skills Training
now because of the finding of the state, but the struggle of all the CILs, the
SILC and small providers may say more about the future of the Employment and
Community First Program.
PART ONE: Tennessee begins a state program that leaves out thestate’s Centers for Independent Living
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