Proposed Amendment to the Home and Community-Based Services Waiver for People with Intellectual and Developmental Disabilities
The Director of the Department of Health Care Finance (DHCF) and the Director of the Department on Disability Services (DDS), pursuant to the authority set forth in the Department of Health Care Finance Establishment Act of 2007 and the Department on Disability Services Establishment Act of 2006, hereby give notice of the intent to submit an amendment to the District of Columbia Medicaid’s Home and Community-Based Services for People with Intellectual and Developmental Disabilities (IDD) Waiver program to the U.S. Department of Health and Human Services’ Centers for Medicare and Medicaid Services (CMS) for review and approval.
The amendment application for the IDD Waiver contains three types of changes to be effective January 1, 2026, as follows:
1. service changes to include new services and updating the scope of specific services;
2. systemic changes that relate to modifying DSP qualifications, HCBS settings qualifications training requirements and person-centered plan development for Service Coordinators, QIDP/QDDP qualifications and requirements, and the modification and removal of performance measures; and
3. set reimbursement rates for proposed new and modified services and DSP living wage rates.
Each of these types of changes are described in greater detail in the sections below.
Service Changes:
Assistive Technology: The District is proposing several changes to Assistive Technology services. The changes are as follows:
1. Clarify SHIFT certification requirements for DDS providers and covered assistive technology goods and services.
2. For each assistive technology that costs under $1,000, require a technology plan as part of the Individual Support Plan (ISP).
3. Require that participants eighteen (18) to twenty-one (21) years of age access EPSDT services for medical/health-related needs under the State Plan before accessing waiver services.
4. Allow only professionals within a provider organization who are not licensed Assistive Technology Specialists, Occupational Therapists, Physical Therapists, or Speech, Hearing, and Language clinicians to be required to obtain certification through SHIFT's Enabling Technology Integration Specialist (ETIS) program to provide assistive technology services.
5. Incorporate the inclusion of clinicians whose specialty is in the area in which assistive technologies are recommended, in the assessment process, to ensure appropriate assessments and technologies are provided per the person's identified clinical needs and increases the person's independence.
6. Allow the inclusion of newer, more innovative technologies to ensure the waiver keeps pace with advances in assistive devices and technologies that enhance independence and quality of life for people with disabilities.
7. Add subscriptions to acquire technology to access assistive technology, if this is an available option, rather than purchase it outright. This model allows for continuous improvements, updates, and maintenance without requiring full reinvestment in new devices or software.
8. Add an extension service for Assistive Technology ongoing services.
Behavioral Supports: The District is proposing to add the Licensed Professional Art Therapist (LPAT) credential as a qualified licensure to provide paraprofessional Behavioral Supports Services and modify language in the Tier-3 behavioral support service.
Companion Services: The District is proposing to modify traditional Companion Services allowable staffing ratio descriptions in the IDD Waiver to reflect the staff-to-person ratio, as indicated in the persons Individual Support Plan (ISP) and Plan of Care (POC), to 1:1, 1:2, or 1:3. The 1:2 staffing ratio will be added to ensure persons residing in HCBS Waiver residential settings (e.g., Residential Habilitation and Supported Living) receive the appropriate staffing ratio to meet their needs during the day.
Creative Arts Therapies: The District is proposing to remove the Creative Arts Therapies Services annual monetary cap and implement an annual limit for units. The removal of the annual monetary cap will ensure that services are not negatively impacted by the living wage increase (LWI).
Day Habilitation: The District is proposing to update the language to reflect the staff-to-person ratio for Day Habilitation Services, as indicated in the person’s Individual Support Plan (ISP) and Plan of Care (POC), to 1:1 or 1:4 for day habilitation and 1:3 for small day habilitation.
Employment Readiness: The District is proposing to update the language to reflect the staff-to-person ratio for Employment Readiness Services, as indicated in the person’s Individual Support Plan (ISP) and Plan of Care (POC), to 1:1 or 1:4 for employment readiness.
Health Assessment and Coordination: The District is proposing to add a new service, Health Assessment and Coordination (HAC), in the IDD Waiver. This standalone urgent care telehealth service will provide specific medical advice on when waiver participants should seek additional or in-person medical treatment via virtual applications and allow the provision of urgent care telehealth services to persons residing in host home, supported living, and residential habilitation settings. People can receive telehealth services in their residential setting, as above-mentioned, and it acts as a triage, but does not duplicate Medicaid services covered under the State Plan. This telehealth service provides a real time health assessment to determine the best clinical course of action, often avoiding unnecessary emergency room visits, and is available twenty-four (24) hours a day, seven (7) days a week by a licensed physician. This telehealth service includes video assistance examinations, prescription refills, treatment plans, and coordination of care, and covers the monthly subscription fee for access to a physician.
In-Home Supports: The District is proposing to modify In-Home Supports services criteria for support hours of forty (40) to fifty-six (56) hours per week. People can receive 40 or more hours of in-home support per week if they have significant needs and meet the criteria of support, as justified and documented in outcomes and goals in the ISP and in-home supports plan.
Personal Emergency Response System: The District is proposing to remove the Personal Emergency Response System (PERS) Services as a standalone service from the IFS Waiver, as PERS is currently a service option under Assistive Technology services.
Remote Supports Services: The District is proposing to clarify all IDD Waiver services that are provided through Remote Supports Services delivery, modify requirements for the monitoring base, sensor alerts and on-call/backup responder staff, add In-Home Supports as a HCBS Waiver remote supports service and modify the amount of time In-Home Supports can be delivered remotely, and modify the risk assessment and plan requirement for remote supports services. Services provided through Remote Supports Services will focus on supporting independence and daily activities to include Supported Living Daily and Periodic, In-Home Supports, Day Habilitation, Employment Readiness, and Supported Employment services. Only professionals within a provider organization who have obtained certification through SHIFT’s Enabling Technology Integration Specialist (ETIS) program can provide remote supports services for residential-based and employment-based services.
State Option to Provide HCBS in Acute Care Hospitals: The District is proposing to add the state option to provide home and community-based services (HCBS), by Direct Support Professionals (DSPs), in acute care hospital settings for the purpose of supporting IDD participants in acute care hospital or short-term institution stays when the necessary non-medical supports are not available in that setting for persons requiring assistance with communication, behavioral stabilization, and/or intensive personal care needs, on a case-by-case basis for the following residential supports and services: Residential Habilitation, Supported Living, and In-Home Supports.
Supported Living: The District is proposing to modify the Supporting Living service definition to specify the current utilization of supported living staffing only services. Supported Living staffing only services are for persons residing in the natural home setting who require supports beyond the scope of in-home supports and without staffing supports and nursing oversight and coordination, the person would be unable to maintain their independence and health and wellness in the natural home. People receiving supported living staffing only supports must own or lease their home.
Telehealth Services: The District is proposing to modify the waiver services that will be provided through Telehealth Services delivery, which will cover professional, clinical and therapeutic services delivered remotely to include the following services:
1. Assistive Technology Services Assessment;
2. Behavioral Supports Services;
3. Creative Arts Therapies Services, including art, dance, drama and music therapies;
4. Family Training Services;
5. Occupational Therapy Services;
6. Parenting Supports Services;
7. Speech, Hearing, and Language Services; and
8. Wellness Services, including bereavement counseling, fitness training, nutrition evaluation/consultation, and sexuality education.
Systemic Changes:
To comply with statutory requirements and improve performance measures the District is also proposing changes and systems improvements in the following IDD Waiver sections:
(1) Appendix B: Proposing two changes: Clarifies Qualified Intellectual Disabilities Professional (QIDP)/Qualified Developmental Disabilities Professional (QDDP) qualifications and requirement of a human services degree and continuing education courses.
(2) Appendix C: Removes the performance measure of Number of non-licensed/non-certified providers that adhered to waiver requirements.
(3) Appendix D: Add qualifications training or competency requirements for HCBS settings criteria and person-centered plan development for Service Coordinators.
(4) Appendix G: Proposing three changes: Removes the performance measures of (1) Percentage of Mortality Review Committee (MRC) death investigations completed within 45 business days from the submission of complete record and (2) Percentage of death investigations reviewed by MRC within 45 business days of the receipt of the death investigation report; and (3) Modifies the performance measure of the requirement for persons to have an annual physical examination.
(5) Appendix I: Proposing two changes: Removes the performance measure of (1) Percentage of claims denied by MMIS and (2) Percentage of provider payment rates that are consistent with rate methodology approved in the approved waiver application.
(6) DSP Qualifications: The District is proposing to remove the requirement for Direct Support Professionals (DSPs) to have proof of COVID vaccinations.
Reimbursement Changes:
(1) Appendix I: Proposing three changes: Adds the DC living wage adjustment rate for DSPs. The District will be adjusting the DSP living wage rate to 117.6%, effective January 1, 2026, contingent upon funding availability; and Removes the performance measures of (1) Percent of claims for IDD waiver service denied by MMIS; and (2) Percentage of provider payment rates that are consistent with rate methodology approved in the approved waiver application.
(2) Appendix J: Proposing five changes: Adds Creative Arts Therapies services and rates; and Adds billing rates for the following services: (1) Assistive Technology ongoing- Extension service; (2) Companion Services (1:2); (3) Health Assessment and Coordination; and (4) State Option to Provide HCBS in Acute Care Hospital Settings.
Public Comment:
There are two opportunities for the public to provide comments or other input on the proposed HCBS IDD Waiver amendment:
1. Written Comments: Written comments on the proposed HCBS IDD Waiver amendment application shall be submitted to: Benjamin Ebeigbe, Director, Long Term Care Administration, Department of Health Care Finance, 441 4th Street, NW, Suite 900S, Washington, D.C. 20001, or via email at [email protected] during the thirty (30) calendar day public comment period, beginning August 15, 2025 and ending September 15, 2025. The public comment/input period will end on September 15, 2025 at 12:00 p.m.
2. Public Forum: DHCF and DDS will hold a virtual public forum during which written and oral comments on the proposed IDD Waiver amendment will be accepted. The virtual public forum will be held on:
Date: Friday, August 22, 2025
Time: 12:00 p.m. to 1:30 p.m.
By Phone: 1-301-715-8592 (Access code: 869 2072 4982)
Web conference: https://us06web.zoom.us/j/86920724982
Accommodations for the public forum are available upon request. Please provide your name, address, telephone number, organizational affiliation, and accommodation request, if needed to Donnise Taylor at (202) 730-1556 or email [email protected].
