PART ONE: Tennessee begins a state program that leaves out the state’s Centers for Independent Living
The state of Tennessee developed a unique service with the new
Employment and Community First initiative. Tennessee Amendment 27 was the first
attempt in the U.S. to bring integration and independence to Americans that
were often trapped on waiting lists for programs. All of the state’s six IL
Centers were asked to be a part of providing the tools to help people with
disabilities all over the state to live independently and to work for
employment and self-sufficiency.
July 1, 2016 the program went live and
MCIL had done the work to build our program and services from scratch. In the
ECF program we offer: Peer-to-peer
Self-Direction; Community support, development, organization and navigation; Health
Insurance Counseling (Forms Assistance) and Independent Living Skills Training. At the time we were also
offering Personal Attendant Services
and Supportive Home Care through our
existing PAS Services department.
MCIL desperately needed more service hours for our PAS program and
those two ECF services seemed to be in demand. Increasing our capacity with ECF
Personal Attendant Services and Supportive Home Care seemed just what the
Center needed to continue consumer oriented
home and community services. MCIL did not get any of the first ECF referrals
and by October we had paid for all necessary training and background checks for
our staff and we had been certified by both Managed Care Organizations.
To date, MCIL has not received a single appropriate referral. We
have heard from five people and some “Support Coordinators” from the MCO’s, but
none were looking for services that MCIL had agreed to provide. One referral
may have included services we offer, but it was from a county outside our area.
Since the beginning of 2017, it has been very hard here at MCIL
because our PAS program dipped below the hours needed to keep it sustainable
and keep the dozens of Direct Support Professionals employed. In March MCIL had
to end the program and two additional professionals who administered the
program lost their jobs. The state’s ECF program said they had 1,700 slots in
the first year but not one appropriate referral came to MCIL.
MCIL did not end its ECF program however, although clearly we
could not offer Supportive Home Care
and Personal Assistance services
because we no longer had a PAS program. The MCOs did not call for any of the
other services that MCIL had to offer.
From the beginning, we had assumed the IL Skills would be our
bread-and-butter. MCIL has more than 32 years of IL experience in the community
and it is our calling-card, it is in our name.
The Memphis Center for Independent Living never removed the
service “IL Skills Training” from our Policy and Procedure Manual but the
Managed Care Organizations apparently could not approve us to provide IL Skills
because, they claimed, an IL Skills provider must have be a “Licensed Day
Habilitation Provider” in order to be credentialed by the Managed Care
Organizations.
The MCO’s did not have any problem with us continuing to list IL Skills as a service we provide,
because they could not coherently explain why we would need a Day Services
license. It did not make any sense. The IL Skills according to the state
regulations could not be provided in a facility and had to be one-on-one
services offered in the least restrictive setting.
From early on in this process, the Statewide Independent Living
Council and other CILs in the state were advocating to get rid of the Day Services
license. The other Tennessee CILs were working on developing ECF programs of
their own and saw the license as a barrier. One-by-one the CILs dropped out of
the ECF program for a variety of reasons, including the burden of the
unnecessary license.
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