The mission of VCDR is to advance the human and civil rights of people with disabilities to ensure full and equal participation in all aspects of community life and the political process.

 

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Part C of the Individuals with Disabilities Education Act (IDEA) provides Early Intervention Services for Babies and Toddlers From the Vermont Family Network and the Vermont Federation of Families for Children’s Mental Health

Here are some Updates on Part C Rule Changes in Vermont:

The major changes in Federal IDEA Part C regulations (Sept. 2011) require that Vermont revise its special education regulations for Part C in order to be in compliance with these rules. The Office of Special Education Programs (OSEP) requires states to provide necessary assurances given the Part C Federal Application and Interagency Agreement (both submitted to OSEP April 2012). OSEP requires that the Vermont Part C rules revision will be promulgated by June 30, 2013.
The Vermont Agency of Education (VTAOE) acts as co-lead with the Agency of Human Services (AHS) to administer Part C. Vermont’s Interagency Agreement for Part C (http://education.vermont.gov/new/html/pgm_interagency.html) delineates roles and responsibilities between agencies. State Part C regulations are included in the State Board of Education Special Education Rules.
The Vermont Special Education rules were opened up for comment in the fall of 2012. Originally the Vermont Family Network (VFN) was told by VTAOE staff that the comment period would close in February, and we agreed to ensure family participation in this phase of rulemaking. Unfortunately the actual timeline had the open comment period closing at the end of December. VFN provided feedback to the VTAOE that this timeline would not allow enough time and opportunity for families to comment, particularly since it took place during the holiday season which is a very busy time for families. The Child Development Division also provided this feedback to the VTAOE, and as a result the timeline for public comment was extended until January 8th. 
We worked to obtain as much feedback for the Agency of Education as we could, given the compressed timeframe and the holidays. More than 150 individuals responded to the proposed changes.
The State Board of Education met April 15th and approved the proposed changes to the Part C rules. Next steps in the process are for the proposed changes to be reviewed by the Secretary of State’s office, then the Legislative Committee on Administrative Rules (LCAR.) VTAOE hopes to have completed the process by May 31. The VTAOE anticipates that LCAR will review and approve the rules on or around 5/16/13, file them with the Secretary of State’s Office, and have them go into effect 15 days after filing.  The most compelling components of the proposed changes to the Part C rules are as follows:
Eligibility for Early Essential Education (EEE)
Currently the Part C rule states: “(1) A child who received special instruction, developmental therapy services or speech services through an Individual Family Service Plan (IFSP) shall be eligible for Essential Early Education (EEE) without need for additional evaluation.” 

The proposed new rule states: 
a) A child who received special instruction, developmental therapy services or speech and language services through an IFSP shall be eligible for EEE if the child meets at least one of the following:
 1) The child is experiencing developmental delays, as measured by appropriate diagnostic instruments, administered by qualified professionals, indicating that the child is functioning at least 25% below his/her chronological age in one or more of the following developmental areas:
i. Speech and language development (expressive and receptive language, voice, fluency and articulation)
 ii. Adaptive development
 iii. Social or emotional development
 iv. Cognitive skills such as perception, memory, processing and reasoning
 v. Physical development
 2) The child has a medical condition which may result in significant delays, and the school based Evaluation and Planning Team has determined that the child is in need of special education.

The current practice of allowing children who have received Children’s Integrated Services – Early Intervention (CIS-EI) services to automatically be found eligible for Essential Early Education services allows for a smooth and appropriate transition for both the family and the child into what is a new and very different system. Families already experience increased stress when their child moves from CIS-EI to EEE, as the family is moving from an Early Intervention system that is built around the family’s needs to one that is focused primarily on the student’s educational needs. This change in eligibility criteria may increase the stress on the family and may complicate the child’s transition into the next setting. It is expected that Children’s Integrated Services partners will continue to support families through their transition to EEE. Capacity varies in the regions, at present.

Evaluation will be based on the ongoing assessment (at the 6-month review) or on the annual review for determining the 25% delay and done by the Early Intervention staff as the review and the annual are required in regulation. The state Part C partners are working with Brooks Publishing to identify how to measure the 25% delay using the current evaluation instruments, the Hawaii Early Learning Profile (HELP) or the Infant-Toddler Developmental Assessment (IDA).

Additionally, a screening option has been added so that parents may opt for that instead of a full evaluation to determine Part C eligibility. Parents need to be appropriately and clearly informed that they have a right to request a full evaluation if that is their preference. Documents are in development and need OSEP approval to ensure this. As always, families may contact VFN to better understand their rights with regard to Part C.

Roles and Responsibilities of Schools and CIS/EI Partners

The proposed rules reflect a change in language such that the schools have Child Find responsibility as the primary referral source for Part C, and will identify, locate, and screen children 0-3. Evaluation responsibility will transfer to CIS/EI for children 0-3. There is a great deal of confusion in the field as to how and when this change will be implemented, and what resources will be available to CIS/EI providers to support the addition of numerous evaluations to their workload. CIS resources are already stretched in many communities, and Child Development Division (CDD) funding for Children’s Integrated Services will not likely increase in the foreseeable future.

It is our understanding that AOE expects the new rules to be approved and be implemented July 1, 2013. However, until the Interagency Agreement is renegotiated and approved by OSEP, the current Interagency Agreement remains in effect, so that LEAs (Local Education Agencies - our schools) are still responsible for the costs of evaluations for initial eligibility even under the new rules. AHS and VTAOE are working on a joint memo to inform the field as to expectations and timelines.

It is our understanding that the rules will be reopened within the next year or so to allow for more substantive discussion and comment on areas not addressed in these proposed changes, as well as others that stakeholders have been asking to thoughtfully review for several years. This is a time of transition for the Agency of Education and the Agency of Human Services, as individual agencies, and as co-leads for Part C in the state of Vermont under our Interagency Agreement. VFN will remain engaged as systems changes that impact children and families are being designed and implemented.

For more information, please contact Pam McCarthy pam.mccarthy@vtfn.org or Christine Kilpatrick christine.kilpatrick@vtfn.org at Vermont Family Network.

 

Integrated Family Services (IFS) A Family Perspective
From the Vermont Family Network and the Vermont Federation of Families for Children’s Mental Health

The Agency of Human Services (AHS) is moving forward with Integrated Family Services, IFS, an initiative that seeks to bring all AHS children, youth and family services together in an integrated and consistent continuum of services for families. The goal is to get more favorable outcomes by giving families early support, education and interventions at a lower cost than the current practice of waiting until circumstances are bad enough to require access to high-end funding streams. The current cost to families of waiting until children are extremely ill or families fall apart before they can get help must be avoided.

As statewide family support and advocacy organizations, Vermont Family Network (VFN) and the Vermont Federation of Families for Children’s Mental Health (VFF) are united in their support of the integration of services for families, including those outside the Agency. Children grow in families, families grow in communities, and communities grow in a state that emphasizes the inherent strengths, gifts, and abilities of all Vermonters.

Both organizations are staffed by skilled parents who have themselves experienced the complexities of the fragmented and confusing “system of care.” We work diligently to ensure that families and young people are heard, and that services are responsive, not reactive. We promote family and youth leadership at individual, community, state, and national levels.

Vermont Family Network promotes better health, education and well-being for all children and families, with a focus on children and young adults with special needs.
The Vermont Federation of Families for Children’s Mental Health exists to support families and children where a child or youth, age 0-22, is experiencing or at risk to experience emotional, behavioral, or mental health challenges.

We ask that policymakers always consider the following questions when considering policy and programs that impact children, youth and families. These are the questions that we too will be asking.

Based on our experience, a successful Integrated Family Services (IFS) will ensure that:

Update on Children’s Personal Care Services (CPCS) From the Vermont Family Network

Snapshot of the Issue:

CPCS is a critical component of support for many families of children with special needs across Vermont, and in some instances the only direct support they receive.  CPCS provides assistance to children with disabilities and chronic conditions to enable them to accomplish self-care tasks that they would typically do for themselves if they did not have a disability. Through the years, the CPCS program expanded dramatically. Many of the children served through CPCS had needs not met by other resources, including supports for behavioral challenges, communication, cueing, and supervision and safety. The State determined that many services accessed with CPCS funding were outside the definition of CPCS and were vulnerable to Federal Audit findings. At the same time that CPCS was expanding, access to waiver services for children decreased significantly, due in part to the narrowing of the Developmental Disabilities System of Care Plan funding criteria.  

Beginning in 2009, the State researched and adopted a new evaluation tool which was expected to more accurately identify needs related to self-care tasks.  Beginning in April 2012, using the new evaluation tool, the State began reevaluating every child’s functional eligibility for personal care services.  This has had the effect of some children not qualifying for the same level of personal care services they had previously. For these children, families are being provided with “transition funding” as a temporary support. This transitional funding, initially for a period of up to one year, provides an opportunity for families to contact their local mental health/developmental services agencies (Designated Agencies) to determine the services and supports their children may still need or access other formal or informal services and supports that may also meet their needs.

Although families received notification of the decisions regarding their child’s CPCS and the availability of transitional funding, families found the letters to be confusing. Some families did not understand that their child’s benefits were reduced or terminated, ending their entitlement to CPCS. AHS allocated funding to the Designated Agencies to increase availability of services for children that better met individual needs, some of which were identified in the CPCS evaluation.  Further evaluation for services and supports includes the needs of the families. It is a work in progress as each region develops services unique to the children and families they serve. 

Hearing the concerns regarding the notices families were receiving, the State revised them.  Since January 1, 2013, the families of newly evaluated children have received the new notices clarifying the CPCS determination.

Families have the right to appeal a Personal Care decision.

 

 

2. There are important timeframes to keep in mind:

3. Families may request both an internal appeal and a fair hearing at the same time. They don't have to exhaust one before proceeding to the other.

4. If they wish to have representation or legal counsel, families may contact Vermont Legal Aid at 1-800-889-2047.

Any family whose transition funding is about to end is strongly encouraged to file an appeal. Families can also contact the Disability Law Project of Vermont Legal Aid.  These families may have received unclear notices, and not understood that their child’s entitlement to services ended when they started receiving transition funds.

The Disability Law Project has been working with the Agency of Human Services (AHS) to ensure that notices are clear and adequate, and that any changes to the CPCS program are legal and compliant with the Social Security Act.  AHS has begun updating the current CPCS Medicaid Rule to accurately reflect how the program is operating.  The current rule has not been substantially updated in almost 20 years.  A temporary continuation of transition funding will continue for all families.  If families have questions or concerns about transition funding, please call the CPCS program at 1-800-660-4427.

The State has circulated an initial draft of the proposed rule.  At a meeting on April 15, 2013, Integrated Family Services Director Melissa Bailey and Deputy Commissioner of the Vermont Department of Health, Tracy Dolan, met with stakeholders to obtain feedback about the rule.  Some of the suggestions made by stakeholders at the meeting are being incorporated into the next version of the rule.  In late May or early June, the State will begin the formal rulemaking process.  At that time, they will issue the updated proposed rule for CPCS.  The public will have an opportunity to comment on the rule by submitting written feedback and by attending a public hearing which is required by law. We understand that AHS plans two public hearings this June, which families are encouraged to attend. Meanwhile, all stakeholders should review the draft of the proposed rule and provide the State with comments (see attached.)  IFS Director Melissa Bailey welcomes comments and questions at Melissa.bailey@state.vt.us .

Changes in the systems of care that impact children with special needs are being designed and implemented at both the state and local levels.  Families and advocates have been engaged in the conversations, particularly at the Vermont Coalition for Disability Rights (VCDR), the Act 264 Board which advises Integrated Family Services (IFS), the State Interagency Team, and the State Program Standing Committees, which advise Mental Health and Developmental Services. 

Advocates are hearing from many families who are worried about losing supports and services that help their children be stable and successful, as the state continues to try and provide clarification as to how children and their families’ needs will be met by other more appropriate resources. 

Early and Periodic Screening, Diagnosis, and Treatment (EPSDT) is a mandate for any state that accepts Medicaid and is a part of the solution as to how Vermont will meet identified needs.  Many services identified as medically necessary for children are an entitlement under EPSDT. Services include therapies, in-home therapeutic and behavioral supports, crisis services, care coordination, personal care services, etc. Children with disabilities and chronic conditions need these supports to live safely in their homes and communities. Other services such as respite are additional services that states may decide to provide but are not required. In Vermont, IFS is trying to increase resources in both the mandated and additional service categories.

The Medicaid Exchange Advisory Board (MEAB) has revived its EPSDT work group. Advocates have shared their concerns with DVHA Commissioner Mark Larson relative to the lack of availability of certain EPSDT services. EPSDT mandates that states inform recipients of the availability of covered services, arrange for covered services to correct or ameliorate physical and mental health conditions, and to actually provide the services with reasonable promptness. We believe that making improvements to the access of services covered through EPSDT would alleviate many of the concerns that Children’s Integrated Services (CIS) and IFS are trying to address, and that families of children with special needs would be better served.

It is critical that families be meaningfully included as the State proceeds with the Integrated Family Services initiative. Disability advocates do support a coordinated and comprehensive system of supports for children and their families. The system must be accessible, and seamless, and truly responsive to the needs of children and their families. Currently, IFS is in its initial stages, with a promising pilot in Addison County. The challenge is that the State is moving forward with changes to CPCS without alternative services being readily available and before IFS is fully up and running. We need to be certain that, as the state implements changes to existing programs like CPCS, it is truly prepared to meet the needs of children who may no longer qualify for CPCS. Family voices should inform that process.

 

The Vermont Family Network and the Vermont Federation of Families for Children’s Mental Health will continue to work with our state partners and engage families in these important conversations about systems change. We will provide more information as it becomes available. For more information, contact Kathy Holsopple, kholsopple@vffcmh.org or Pam McCarthy, pam.mccarthy@vtfn.org

People with Disabilities in Vermont           
Who are they/WE!?!
By Ed Paquin

Here are some FUN FACTS, except that these are actually true!
WE HAVE A POPULATION OF ABOUT 621,270 in Vermont. (estimate for ‘08)
466,000 of those Vermonters are over 18 years old and (according to the Behavioral Risk Factor Surveillance Survey) of those, 89,000, or 19.1% are people with disabilities.

People 5 yrs. and older in VT 582,765 total 93,507 with disabilities or 16%
People 5-15 yrs old in VT 80,992 total 7,227 with disabilities or 8.9%
People 16-20 yrs old in VT 48,283 total 4,841 with disabilities or 10.0%
People 21-64 yrs old in VT 373,129 total 51,417 with disabilities or 13.8%
People 65 and older in VT 80,361 total 30,022 with disabilities or 37.4%

How can we picture a number like that?

Well, add up the population of the 4 largest cities and towns in Vermont, then throw in a couple of small ones and you get about the right number. In other words the entire populations of:

Burlington 38,897
S. Burlington 17,574
Essex  19,649
Colchester  17,237
Landgrove 137 
Buell’s Gore 12

Equals 93,506 people, still one less!

Disability types vary by age but for working aged Vermonters, ages 16-64, (56,258 total) the types of disability, in real general terms break down like this                                               

12,332 sensory or 22% 
30,452 physical or 54%
24,439 mental or 43%                   

The total is 119% because some have multiple disabilities.


Of working age (16-64) Vermonters without disabilities (365,154) 294,388 (or 80.6%) are employed meaning 19.4% are not!!
Of working age (16-64) Vermonters with disabilities (56,258) 25,974 (or 46.2%) are employed meaning 53.85% are not!!
57.2% of working age Vermonters w/sensory disabilities are employed.
40.5% of working age Vermonters w/physical disabilities are employed.
38.9% of working age Vermonters w/mental disabilities are employed.


8% of working age Vermonters without disabilities are living in poverty.
21.7% of working age Vermonters with disabilities are living in poverty.
15% of Vermonters w/sensory disabilities are living in poverty.
21.4% of Vermonters w/physical disabilities are living in poverty.
27.2% of Vermonters w/mental disabilities are living in poverty.

And by the way, Vermonters w/disabilities who are employed are paid only 54.5% of what people w/out disabilities earn.


29.3% Vermonters w/out disabilities aged 18-34 are enrolled in college or graduate school.
21.1% of Vermonters w/disabilities aged 18-34 are enrolled in college or graduate school.

But really, what does this mean?  Who are we?

In general “a person with a disability” under the ADA, is an individual who:

This is your grandmother if she can no longer get around in the way that she did when she lived independently!
This is your uncle when he lost his hearing.
This is your brother who came back from Iraq with a head injury.
This is the guy you work with who has been secretly living with what he brought back from Viet Nam 40 years ago.
This is the young woman who is struggling with her school work because her ability to concentrate has been shot since her cousin raped her.
This is that neighbor’s son who went to a hospital instead of college when he started hearing and seeing things that weren’t there.
It also includes folks like the young woman I know who worked at Wyeth with the help of accommodations for her macular degeneration.
This is the six year old who lived near me in Fairfax who couldn’t learn like the other kids, who had one leg that didn’t quite let her run like the other kids and who was staying in a “different” home because she was getting lost in the shuffle as her mother went from place to place following jobs and men.
This is that neighbor down the street who has never heard a sound in her life, didn’t have the opportunity to go to a school like the Austine and was often seen walking around town with people acting like she wasn’t there.


A key thing to remember is that disability is a natural part of life and not a reasonable basis to exclude people from the benefits of our society, which, even in the time of recession, is the richest society that history has ever known.


This is well summed up in this ADA Quote:
individuals with disabilities are a discrete and insular minority who have been faced with restrictions and limitations, subjected to a history of purposeful unequal treatment, and relegated to a position of political powerlessness in our society, based on characteristics that are beyond the control of such individuals and resulting from stereotypic assumptions not truly indicative of the individual ability of such individuals to participate in, and contribute to, society;

The ADA also excludes some:
Who is NOT:  A person who currently illegally uses drugs is not protected by the ADA, as an "individual with a disability," when the covered entity acts on the basis of such use. However, an individual who is engaged in or has completed drug rehabilitation and is no longer illegally using drugs is protected under the ADA. Homosexuality and bisexuality are not impairments and therefore are not covered by the ADA. The Act also states that the term "disability" does not include the following sexual and behavioral disorders: transvestitism, transsexualism, pedophilia, exhibitionism, voyeurism, gender identity disorders not resulting from physical impairments, or other sexual behavior disorders; compulsive gambling, kleptomania, or pyromania; or psychoactive substance use disorders resulting from current illegal use of drugs.

Why do you folks in public service need to be concerned with all of this? United States law, as quoted above AND Vermont law recognizes that people with disability have a right to the same opportunity and the same benefits that other non-minorities have access to.

The most significant source of ongoing economic support for folks with disabilities who don’t or can’t support themselves or whose families don’t or can’t support them is from the federal Social Security SSDI or SSI.

In December 2007, 13,920 Vermonters received SSI,
1,117 were aged,
87 were blind and
12,716 were otherwise disabled.
1,732 of these were children under 18.

In December 2007, 20,183 Vermonters received SSDI
17,733 were workers themselves,
2,006 children and
444 widows or widowers.

State services to address the needs of PWDs are broader than they are deep, considering the pressure that the recession has put on State budgets.  Think of all our long term care programs. Not just nursing home care or community care under the Choices for Care Program, but the CRT program for people with Serious and Persistent Mental Illness, Developmental Services for people with Developmental Disabilities. We partner with the federal government in most of these programs, as we do with our vocational rehabilitation and services to the blind. We add some to the SSI program through our “AABD” program. We assist people with sensory needs to get help with their telephone equipment.  We have programs set up to protect “vulnerable” adults and children from abuse and neglect. And our Medicaid program has many acute care services that are of great import to people with disabilities, particularly children.
Perhaps the most fundamental disability rights program in the State is funded by the State, Local AND Federal governments – that’s Special Education which serves a wider range of students than most people generally picture.

Nationally, in the fall of 2007 11.3% of students aged 6-17 received IDEA, Part B services or “Special Education” (I don’t have the Vermont numbers on this.)
Nationally Special Education students had these disabilities:

Specific Learning disability  43%
Speech or Language Impairment 19%
Mental Retardation 8%
Emotional Disturbance 7%
Multiple Disabilities  2.2%
Hearing Impairment 1.2%
Orthopedic Disability 1%
Other Health Issue   11%
Visual Impairment  .4%
Autism 4%
Deaf/Blind     .02% 
Developmental Delay   1.5%


I will leave you with one other thought: unlike some countries, many of the services for people with disabilities in the United States, and in Vermont, are based on our American conception of civil rights and the right to of all Americans to live independently. In many instances our system, particularly since laws like IDEA and the ADA passed, serves to redress the inherent discrimination people with disabilities have faced throughout history. The choices you make in the next session will show whether you will continue to help with this liberation or will make policy decisions that serve to constrain people to live in poverty and DEpendence.

 

Initial VCDR Response to the First Challenges Progress Report

Date: April 6, 2010
To: Joint Legislative Government Accountability Committee
From: Vermont Coalition for Disability Rights
Regarding: Initial VCDR Response to the First Challenges Progress Report

VCDR member organizations have prepared more in-depth comments on specific sections of the Challenges Progress Report. This summary provides an overview of our concerns.

General Observations

Many of the administrative goals highlighted by the Administration (better coordination of AHS functions and services, reduction of some of the fragmentation of services, improved use of IT and state funds to better serve individuals and families, and support of real opportunities for Vermonters) make sense. However, we did not see adequate thought given to viable outcomes, methods and financial analysis to support the stated goals of most sections. Many of the administrative goals seem like activities that have significant up-front costs and will not lead to immediate cost savings, though these may occur over time.
There are many ways that state government can better address the needs of individuals with diverse disabilities and their families throughout life and that there are ways that a more coordinated approach can greatly improve service delivery systems and result in more responsive person and family centered support. This is a discussion that needs to be part of a multi-year planning process and cannot be hammered out in a few weeks. Designing a results-based agenda that furthers equity, inclusion and positive social outcomes for individuals and families should lead to better personal and social outcomes for individuals and families, and improved coordination and efficiencies; but many of the efficiencies proposed in this report will actually be detrimental to some individuals and families who look to state government for help.

The need to protect vulnerable groups: We oppose proposals that would use the Challenges initiative to reduce rights protections and financial safeguards for vulnerable groups of Vermonters. We oppose using this initiative to weaken forced treatment protections for individuals with mental health conditions (DMH); oppose the proposal to expand use of estate recovery in long term care services (DAIL); and oppose any proposals in the Challenges progress report that deny Vermonters the right to receive services during an appeal process.
The timing of this process allows too little time for thoughtful consideration of some of the legitimate elements of the Challenges initiative and leaves too many Vermonters out of the discussion. Public hearings and related outreach activities need to be accessible: sign language interpreters, web based and print information and different outreach activities need to be accessible.

Responses to Specific Proposals

Information Technology Improvements- No real cost analysis was provided. Many of the state goals make a great deal of sense but there is too little information to evaluate this initiative in relation to the goals of the Challenges legislation. Costs could be significant and most savings will not be immediate. Any IT work and contracts should include clear guidelines for accessibility in hardware, software and information.
Integrated Children and Family Services: The problem statements represent real concerns and have been the focus of several planning groups and policy reports. The broad vision of this initiative is appropriate.  However, the outcomes chart in the Challenges Progress Report does not reflect input from families and the actual action steps proposed are incremental and in some cases counter to achieving comprehensive change.  The Integrated Family Services Progress Report lacks health-related disability perspective, and lacks steps to integrate services provided in schools.
The planning process and structure of committees instituted by AHS a few weeks ago seem like a thoughtful planning process, but we are just now being invited to participate in the planning and there are significant concerns and unresolved issues. The focus needs to be expanded to include the concerns of individuals with disabilities moving toward adulthood and not just early childhood issues and services. The intent of both the IFS and Integrated Child Development Initiative (CIS) should be to promote a developmentally appropriate lifespan approach in the planning and provision of services to children and families.

Blueprint for Health and Related MH Initiatives: We believe that integrating the health concerns of individuals with disabilities into the blueprint medical home initiative should lead to better health outcomes and related savings. We are glad to see that the DMH is looking at ways to promote wellness and healthy living support for individuals with mental health conditions as this has been an important element of Vermont's peer support and recovery work. For people to be well served by the Blueprint for Health, partnering with primary care practices, specialists and local community organizations needs to integrate individuals with disabilities into their Blueprint initiatives and the State needs to be providing the systemic leadership and support to ensure that the health needs of Vermonters with disabilities are not left out of Blueprint planning, implementation and development as they repeatedly have been in past Blueprint initiatives. The system needs to plan for accessibility in information and services and providers need education and ways to work with disability and senior programs to integrate social as well as medical supports. A great deal of money is being committed to the Blueprint infrastructure and related outreach. Grants and contracts should be clear about accessibility needs and requirements so that individuals with disabilities benefit along with other Vermonters. This makes sense and will result in significant savings in health care costs in the future.

DAIL

Services for Adults with Physical Disabilities and Older Vermonters: VCDR supports a renewed commitment to funding alternatives to expensive nursing home care and creating related incentives for this to happen. For this to work, a sufficient amount of the savings from when people leave nursing homes needs to be protected and reinvested in other community based options. We appreciate DAIL's interest in creating more flexible funding and services options for those who want them and believe that it makes sense for the needs and preferences of individuals to shape services. DAIL hopes to reduce funding for direct services but better serve people in CFC and other programs through greater flexibility. We are very concerned about finding Challenges savings through reductions in services and would like to see more specific proposals so we can assess their impact. The CFC program, the Attendant Service Program, and other DAIL services for seniors and individuals with disabilities have had significant funding taken away over the last few years. DAIL's long term care and independent living services need to be adequately funded or people's health, safety and independence will suffer, as has already happened over the last few years. Moving to presumptive eligibility makes sense and saves time as well as administrative costs.

Many of DAIL's proposed activities have merit but lack the necessary analysis for us to assess their viability at this time. VCDR members are very concerned about structural changes being approved too quickly without adequate care - and consideration of the impact on rights and services.

Developmental Services: Many of the proposals DAIL has made to improve management of the Choices for Care Program build on some of the best features of the DS system and individuals and families served by the DS system are very concerned that challenges initiatives not be used to erode the very approaches that have been developed over years. Joan Senecal has said that the only way she sees to reach Challenges saving objectives is to continue to cut services. VCDR members would prefer not to see cuts to DS services - or other DAIL services - as these programs have already taken repeated cuts. Individuals and families have told VCDR member organizations that they would rather have 5% cuts made in their individual services than in program budgets for targeted case management and flexible family funding. This way they would at least maintain some control and authority in how cuts are made and can make choices that support the most important goals and outcomes for them. Hopefully there will be a more thoughtful process for assessing other administrative savings that might be possible in DS system's administrative practices that could reduce or take the place of service cuts.

Creative Workforce Solutions: We were pleased to get clarification from VR that some earlier proposals that would have changed DS services are no longer part of the proposed employment initiative and that DS supportive employment and community support funding will remain intact and independent, though DS providers will be an important part of the regional initiatives. VR has done some very successful work with Reach Up and TANF recipients in the past and there is a lot in this proposal that makes sense. Again, additional financing and cost benefit information and analysis is needed. We also want to make sure that an expanded role for VR does not reduce their ability to serve current recipients of VR, those who meet the federal definition of eligibility for their services.

Thank you.
Deborah Lisi-Baker, President
Vermont Coalition for Disability Rights

Contact VCDR

To Contact VCDR by mail:
VCDR
11 East State St., Suite 2
Montpelier, VT 05602

VCDR can be contacted by phone via VCIL at:
Phone: 1-800-639-1522