The Illinois Department of Human Service has proposed new appeals rules and public
hearings. The Arc opposes the proposed rules, see our testimony and locations of the
Comments for Illinois Department of Human Service proposed
new appeals rules public hearings
August 21, 2015
Faye Manaster, M.Ed., Project Director
Tony Paulauski, Executive Director, The Arc of Illinois
Thank you for this opportunity to provide public comment on the proposed rules
The Arc of Illinois opposes these proposed rule changes.
We urge you not to make any changes to the appeals process for Illinois recipients
of public benefits.
The proposed changes will establish a more restrictive and complex appeals process
will only serve to make these barriers insurmountable.
Over the past few decades, the various programs of The Arc of Illinois have received
numerous requests for assistance from families of persons with disabilities, self-
advocates, providers and care coordinators when their applications for state benefits,
including Medicaid, SNAP, TANF and Home and Community Based Services, have
been erroneously denied .
In other cases, persons receiving benefits have had their eligibility mistakenly
terminated or have received “30 day notices” of impending termination of services. In
some instances, individuals or families have been barred from even applying for
benefits for which they are eligible.
These types of unfortunate and mistaken encounters with the public benefits systems
in our state are especially frightening and stressful for individuals with disabilities, both
children and adults, and their families, as both their access to Medicaid health
insurance together with essential Home and Community Based waiver support services
are at stake.
Up to now, the Illinois Department of Human Services has had a clear-cut and
straightforward appeals process for individuals in these situations.
We have been able to provide information and guidance to thousands of individuals,
families and professionals over the years regarding appeal rights, the entire appeals
procedure, and follow-up steps.
Making changes to the individual’s right to appeal is in conflict with not only some state
and Federal regulations but could have the devastating effect of increasing
institutionalization of children and adults with disabilities if they are no longer able to
obtain health insurance, support services or even their daily sustenance.
Fortunately, The Arc of Illinois maintains excellent collaborative relationships with the
Illinois Department of Human Services Division of Developmental Disabilities and the
Illinois Department of Healthcare and Family Services. Due to these relationships, we
are frequently able to assist self-advocates, families and guardians to resolve eligibility
and access issues on the case advocacy level. However, on occasion, utilizing the
appeals process is necessary to resolve some issues.
Our decades of experience inform us that the current right to appeal and the entire
appeals and hearing procedures need to be left intact.
The most vulnerable residents of Illinois, together with their families/guardians, may be
endangered if their appeal rights are modified and restricted.
As a state, we simply cannot afford the monetary or human cost of restricting access to
vital services and supports by means of making the appeals process even more
difficult and complicated. The individuals and families whom we represent face more
significant barriers than some other recipients of public benefits in their daily lives do.
A more restrictive and complex appeals process will only serve to make these barriers
On their behalf, we urge you not to make any changes to the appeals process for
Illinois recipients of public benefits.
The hearings are scheduled for:
Tuesday, August 25, 2015 10:00a.m. – 12:00p.m.
Michael J. Howlett Building
2nd & Edwards Streets
Wednesday, August 26, 2015 1:00p.m. – 3:00p.m
Michael A. Bilandic Bldg.
Auditorium Room C-500, 5th Floor
160 N. LaSalle
Tony Paulauski Executive Director
The Arc of Illinois
20901 S. LaGrange Rd. Suite 209
Frankfort, IL 60423