Arc Comments on New CMS Rules on Community Services
Preliminary Comments on Transition Plan for New CMS Rules on Home &
Community Based Services
February 4, 2015
First of all I would like to thank you for allowing The Arc to co-host the Listening Forum
with the Dept. of Health Care & Family Services. In particular, I appreciate your
Today I will only make a few general comments and submit more extensive
recommendations at a later date online. I will share with you two new definitions for
consideration as an amendment to the Adult Home & Community-Based Waiver that will
move Illinois toward CMS compliance.
Individual & Residential Community Support Services
Both of these draft definitions have been shared with Director Casey of the Division of
Developmental Disabilities in our discussions of the Developmental Disabilities Work
Group on the 1115 Waiver and the need for new definitions.
First and foremost, The Arc supports the implementation of the new CMS Rules on
Home & Community-Based Services. The rules’ focus will lead Illinois to a person-
centered system based upon the needs of the individuals we are here to support.
The Illinois Developmental Disability Community System is terribly underfunded and
relies heavily upon institutional services. If you analyze the spending, you will see that
we fund day and residential services in groups not tailored to individualized supports
required for person-centered planning. In my opinion, the Illinois system will have to
change dramatically and invest in community supports if we are to achieve the
standards set before us with the new CMS Rules.
Another area that will require attention is how we will organize to insure that there is
actual compliance with the new CMS Rules. Is there a plan to train the Individual
Service Coordination Organizations and their staff on these new rules?
Also, how do we interview participants about: choice of residence, community access
and integration, living space, staff interactions, privacy and services on an ongoing
More on the Transition Plan later, but I believe it needs a lot of work as does the