Comments on the Customize Rate Guidance Document

7.2: SPONSORED RESIDENTIAL

• Customized rate funding approved for Sponsored Residential Supports cannot be used to increase the sponsor payment directly.  
  
  
• Funding approved shall only be used to pay for and provide additional staff, not including the sponsor(s), who are necessary to provide the 1:1 or 2:1 supports required to ensure the health and safety of a qualifying individual.  

• Families, caregivers or other individuals who maintain full time residential status in the home where the
  qualifying individual is receiving services, shall not be included in the customized rate request for additional 1:1 or 2:1 staffing.  
  
  
• Families or caregivers acting as the sponsor are required to provide a minimum of 40 hours weekly of support to the individual before customized rate funding can be approved to cover the cost of paying for or hiring additional staff.
  
  
• Eligible providers must indicate that they have met financial thresholds as outlined in the sponsored residential rate model for paid staff, not including the sponsor.  

The proposed language within section 7.2 related to Sponsored Residential and Customized Rates contradicts itself and makes incorrect assumptions about the requirements of anyone living in the home of a Sponsored Residential Provider. Sponsored Residential Services do not require that a Sponsor be married or have another person who lives in the home that is not receiving services. Other adults who live in the home may work in jobs outside of the home and the Sponsored Service. They may not have any additional training and only have their backgrounds completed.

Adults, other than the identified Sponsor, living in the home must be counted separately in the customized rate application if they choose to work in the home and are hired and trained by the identified Sponsor to provide DSP Services. This would include spouses, significant others, adult children of the sponsor or hired adults who live in the home and are trained to provide DSP Services within the setting. The criteria within this section forces the committee to count 2 or more people providing services and living in the home as one person within the Customized Rate Model. This proposed guidance could discount hundreds of hours of work being provided by other Direct Support Professionals living in the setting.

If a Direct Support Professional is hired, trained and paid by the identified Sponsor then the hours worked by the DSP should be counted toward the customized rate regardless of where they live or any other status they may hold such as spouse, significant other, adult child or live-in DSP. This would not be increasing the identified or contracted Sponsored Provider payment or 40 hours, simply recognizing the staff necessary to provide the service who are hired, trained and paid by the sponsor/host.

Section 7.1

This section needs clarity. It reads as if Residential Provider A receives a CR for providing services to an individual, that the same individual can no longer receive services from CE/CC Provider B because of the addition of the language “and reimbursed” in the last sentence of this section. This is not believed to be the intent, but unfortunately this is unclear. An individual should be able to receive CE/CC or Group Day Services whether or not a Residential Provider is approved for CR.  

Acceptable Degrees are listed in section 6.4. In multiple places throughout the document, it is stated the degree list is in Section 6.3.