Wednesday, November 2, 2005
|
TO: |
Kim Belshé, Terri Delgadillo , Dennis Boyle, Joe Carlin, Eva Lopez Brian Koepp, Diane Cummins, Peggy Collins, Gail Gronert, Anastasia Dodson, Christian Griffith, Sue North,
Casey McKeever, Chantele
Denny, Julianne Huerta |
|
FROM: |
SEIU Local 434b; Herbert M. Myer, IHSS consumer; IHSS Public Authority of Marin; United
Domestic Workers; California
Association of Public Authorities; Home Care Council; Grey Panthers; OWL; Quality Home Care
Coalition; Janie Whiteford,
IHSS consumer advocate; Protection & Advocacy, Inc. (PAI) |
|
RE: |
IHSS Quality Assurance Initiative: Request for continuation
of process |
We appreciate that CDSS has made significant efforts
toward an inclusive and productive stakeholders
process. A great deal of work has been
completed and many of the mandates contained in SB 1104 to develop a quality
assurance initiative have been completed in accordance with statutory deadlines
and with the concurrence of stakeholders.
However, we have significant concerns in three areas, outlined below.
The most complex, significant and potentially controversial piece pertaining to
the development of Hourly Task Guidelines requires additional time and thought
and we respectfully request that a more reasonable timeline to do justice to
this effort which affects so many Californians.
SB 1104, enacted in 2004, established an IHSS Quality
Assurance Initiative. One of the most
complex requirements of SB 1104 is for the California Department of Social
Services (CDSS) to develop statewide hourly task guidelines and instructions to
provide counties with a standard tool for consistently and accurately assessing
IHSS service needs and authorizing service hours to meet those needs. Under current law, CDSS must complete the
development of the statewide hourly task guidelines, including exceptions to
those guidelines, and adopt regulations by June 30, 2006. In accordance with state law, CDSS has
established a process to obtain input from stakeholders.
CDSS staff has made substantial efforts to obtain data and
solicit input from stakeholders to develop hourly task guidelines. Numerous workgroup meetings have been held
and a great deal of effort has gone into the job of finding and developing data
sources that could be used to develop the hourly task guideline ranges.
While recognizing the effort that CDSS has made to provide
data, we are very concerned about the reliability and accuracy of the data that
has been shared with workgroup participants. Reliable data is essential to
ensure that the hourly task guidelines that are developed comply with the
statute and accurately “specify a range of time normally required for each
supportive service task necessary to ensure the health, safety and independence
of the recipient.”
One of CDSS’s primary data
sources is the Case Management Information and Payrolling
System (CMIPS). CMIPS is a
twenty-year-old information computer system that tracks IHSS case information
and processes payments to providers.
CMIPS does not provide data on the number of hours that are normally
required for each consumer to live safely in their home. It only reports the hours that have been paid
for service – not what is actually needed.
Notwithstanding the numerous concerns that have been expressed by
stakeholders about CMIPS data, this is the data that is used most commonly in
the workgroups in discussing and developing potential time-for-task ranges.
CMIPS data reflects the current inequities and differences between counties in
approval of IHSS hours. Clearly, relying on CMIPS data will not produce the
statutorily required “range of time normally required for each supportive
service task necessary to ensure the health safety and independence of the
recipient.”
To comply with SB 1104, CDSS must obtain and use data
reflecting the actual range of time (taking into consideration variations such
as “good days” and “bad days”) necessary to ensure the safety and independence
of consumers. That leads to our conviction
that field testing is essential prior to the development of hourly task
guidelines. CDSS has conveyed “that the
field data test of the Hourly Task Guideline will occur during the same period
of time that the regulations are being moved forward through the regulatory
process. “ This puts the cart
before the horse and means that draft guidelines and draft regulations will be
based on data about current utilization rather than the normal ranges of time
actually needed to ensure safety and independence of consumers.
The next and seemingly last meeting of the Hourly Task
Guidelines Workgroup has been scheduled for November 3rd. We have been consistently advised that CDSS
will release draft regulations in early December in order to comply with the
June 30, 2006 deadline for regulations to be enacted. We
are profoundly concerned about the lack of field testing and accurate data to
develop hourly task guidelines and believe that additional time is needed to
comply with the law and produce credible guidelines which comport with the
intent of SB 1104.
Accordingly, we are requesting that November 3rd
workgroup meeting be agenda changed to focus on the continuation of the
process. We further request a meeting with principle representatives of the
stakeholder organizations as soon as possible to explore ways to resolve
concerns that have been expressed on numerous occasions about this process.
SB 1104 also requires CDSS to develop a standardized
curriculum, training materials and work aids on the IHSS uniformity
system. CDSS has established the IHSS
Training Academy under contract with CSUS and is budgeted to train
approximately 2500 individuals in their Phase I training program. IHSS stakeholders, including CFILC,
Protection & Advocacy, SEIU, UDW and IHSS advisory committee members have
requested access to training sessions. At our October 13th meeting,
CDSS staff suggested we would receive access.
However, there has been no follow-through. We await information enabling
the stakeholder community to participate in these sessions.
Workgroup participants and stakeholders have repeatedly
expressed concerns and criticisms about accessibility issues. Meetings of the workgroup are always in
Sacramento and, despite all efforts of CDSS to improve the quality of
conference calls, the phone-in system is a source of
major frustration. Callers are often
unable to hear and participate in a meaningful way. While meeting materials are distributed by
email and at the workgroup meetings, these essential documents are often not
posted on the CDSS website on IHSS Quality Assurance. To remedy the situation, we are requesting
that:
1. All working materials and documents be posted and accessible on the CDSS website on IHSS quality assurance at least 72 hours before meetings;
2. All training materials, including manuals and curriculum, be posted and accessible on the CDSS website;
3. All meetings be fully accessible, including fully functional phone access; and
4. Future meetings be later in the day, preferably in the afternoon, to accommodate the participation of people with disabilities.
Thank you for consideration of our requests, made on
behalf of IHSS consumers and providers.