The Arc of Florida Comments to Proposed Amendment for iBudget Waiver: The Agency for Health Care Administration (AHCA) submitted a request to amend its iBudget Waiver, which operates under Section 1915(c) of the Social Security Act, to the Centers for Medicare & Medicaid Services (CMS). The purpose of the amendments is to come into compliance with the HCBS Settings Rule. The Arc of Florida submitted the following recommendations:
ACHA should request an extension to come into compliance with the Rule.
The amendments should not reduce options or choices, contrary to the goal of the Rule.
ACHA should review all guidance from CMS since the Settings Rule was promulgated.
In its definition of Day Habilitation, ACHA should add a reference to prevocational or vocational training, and life skills to acquire job opportunities, and not remove the reference to employment.
ACHA should change the term “Adult Day Care Center” to “Adult Day Training or Care Center” or “Day Habilitation” which fairly represents all options of day service.
ACHA should change the time-limit on Prevocational Services from “36 months” to “48 months with the option to renew.”
ACHA should keep the federal language of “optimal outcome” (not change the language to “successful outcome.”) Additionally, ACHA should add that the “optimal outcome is defined by the person.”
For those who want to see the entire slate of comments that The Arc of Florida filed with AHCA, please email ceo@ArcFlorida.org. The Arc of Florida has offered to assist AHCA/APD in making sure Florida’s compliance with the Settings Rule meets the objectives of the Rule to provide individuals with choices and ensure their rights and opportunities for integration.