Friday, June 6, 2025
UPDATE: The attached IFS Waiver renewal application includes updates made to Appendix J. The public comment period will be extended for thirty (30) days from the date of this post. The public comment period will now end on July 6, 2025.
The last paragraph of the attached public notice references the incorrect website address on DDS website to view the summary of all proposed substantive changes in the HCBS IFS waiver renewal application.
Proposed Renewal to the Home and Community-Based Services Waiver for Individual and Family Support
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 Individual and Family Support (IFS) Waiver program to the U.S. Department of Health and Human Services’ Centers for Medicare and Medicaid Services (CMS) for review and approval.
The renewal application for the IFS Waiver contains three types of changes to be effective October 1, 2025, as follows:
1. service changes to include new services and updating scope of specific services;
2. systemic changes that relate to modifying staff training requirements, DSP and PDW 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 service and DSP living wage rates.
Each of these types of changes is 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.
Creative Arts Therapies: The District is proposing to remove the Creative Arts Therapies Services annual monetary cap and implement an annual limit for units, effective January 1, 2026. 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.
Individual-Directed Goods and Services (IDGS): The District is proposing to modify Individual-Directed Goods and Services (IDGS) by removing the non-medical transportation requirement. Also, IDGS will only be available to participants who are enrolled in the Participant-Directed Services (PDS)/My Life, My Way program and receiving at least one of the following services: In-Home Supports, IDS 1:1, or Companion 1:1 services.
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.
Participant-Directed Services (PDS): The District is proposing to clarify the provision of transportation is not required for Participant-Directed Workers (PDWs) providing in-home supports services to participants, and staffing ratio of the PDS delivery option for the following services: (1) Individualized Day Supports (IDS) 1:1; and (2) Companion 1:1.
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 IFS 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 In-Home Supports, Day Habilitation, Employment Readiness, and Supported Employment services. Also, only professionals within a provider organization who have obtained certification through SHIFT’s Enabling Technology Integration Specialist program can provide remote supports services for residential-based and employment-based services.
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 IFS 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; and Modifies the IFS Waiver, My Life, My Way program training and qualification requirements for Participant-Directed Workers (PDWs).
(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 E: The District is proposing to update the training requirements for Participant-Directed Workers (PDW) in the My Life, My Way program/Participant-Directed Services (PDS) when providing Companion, Individualized Day Supports, and Respite Services, and modify PDW qualifications to remove barriers in providing self-directed services.
(5) Appendix G: Proposing three changes: Modifies the performance measure of the requirement for persons who reside in natural home settings in the IFS Waiver to have an annual physical examination; Removes the performance measures of (1) Percentage Mortality Review Committee (MRC) death investigations completed; and (2) Percentage of behavior support plans (BSPs) approved by DDS Restrictive Control Review Committee (RCRC).
(6) DSP and PDW Qualifications: The District is proposing to remove the requirement for Direct Support Professionals (DSPs) and Participant-Directed Workers (PDWs) to have proof of COVID vaccinations, and for PDWs to have a high school diploma or general equivalency degree.
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 IFS 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 two changes: Adds Creative Arts Therapies services and rates; and Adds billing rates for Assistive Technology ongoing- Extension service.
Public Comment:
There are two opportunities for the public to provide comments or other input on the proposed HCBS IFS Waiver renewal:
1. Written Comments: Written comments on the proposed HCBS IFS Waiver renewal application shall be submitted to: Benjamin Ebeigbe, Acting 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 May 16, 2025 and ending June 16, 2025. The public comment/input period will end on June 16, 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 IFS waiver renewal will be accepted. The virtual public forum will be held on:
Date: Friday, May 23, 2025
Time: 12:00 p.m. to 1:30 p.m.
By Phone: 1-646-931-3860 (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].
