job searching, self-employment support, supported employment, and other services. The Department’s education of and collaboration with persons with disabilities, family members, providers, Supports Coordinators, employers, and other state agencies needs to be systematic and widespread. Participants also need opportunities to learn about work incentives and maintaining benefits while working. 8 A decision is needed to implement a statewide system for a robust data collection to measure change during each fiscal year in both quantitative and qualitative measures. Reports should be made public. *One other similar comment was received EmployStat used in Philadelphia and Chester County is an existing data system that has many of the required features and could be modified as needed and expanded for statewide use. Too much time has already been lost; another year of data will be lost. At a minimum, collect provider data to establish a baseline for this year. The ODP consulted with the Statewide Employment Leadership Network (SELN) to determine what data should be collected and how to capture it using enhancements to our current system or a stand-alone system for data collection. Reports will be made to the public when this is completed. The ODP will be using many of the features of the EmployStat System used in Philadelphia and Chester County in enhancements to our current system or a stand-alone system. 9 We encourage ODP to add the necessary employment information fields to current data collection systems as quickly as possible. The transition plans currently reflect exploration of employment data collection systems and the timeframes in which ODP believes this can be accomplished. 10 Examine best practices for providing employment supports. Develop plans with providers in how to build skills through training and technical assistance, in providing employment services and home and community habilitation services. Engage providers in identifying what is necessary to accomplish the desired outcomes and developing strategies to be successful. Without adequate attention to building capacity, the service system will not meet the needs of the individuals it is intended to serve. The ODP plans to engage providers to identify changes needed to the current system to increase employment outcomes.
*Six similar comments were received 2 A public information and campaign for participants and family members is needed. The Outreach and Engagement section in each transition plan is a good start. Plain and person-first language should be used. Communications should be accessible. Providing information to the Medical Assistance Advisory Committee is not enough. Email lists, Supports Coordinator visits, local meetings, work groups, webinars, advisories, and letters are also needed. The Department should involve self-advocates. Peer training should be funded, especially for those in segregated settings, to complement the Departments own obligations to educate. *One other similar comment was received The Department agrees that more information should be made available for participants and family members. The Department is currently working on documents that will provide an overview of the CMS Home and Community-Based Services (HCBS) Final Rule that will be made publicly available. ODP is also working on webinars that will provide general information on the CMS HCBS Final Rule to Administrative Entities, Supports Coordination Organizations, and Supports Coordination Agencies. While these are examples of some initial projects the Department is engaged in, the Department is committed to ongoing engagement and education of all stakeholders impacted by any changes made. 3 The action description is “On-going engagement highlighting updates and revisions to Pennsylvania's regulations, policies, and procedures; training on compliance to the Home and Services (HCBS) Final Rule and transitioning activities for service coordinators, providers, and staff.” The people most impacted by changes in the system are people with disabilities and families. They should have ready access to the same training about the rules, regulations and changing business practices as professionals. We recommend this be amended in all transition to add people with disabilities and families. This action step and description should be revised to read: “Stakeholder Training” with the description “On-going engagement highlighting updates and revisions to Pennsylvania's regulations, policies, and procedures; training on compliance to the HCBS Final Rule and transitioning activities for people with disabilities, families, service coordinators, providers, and staff.” *One other similar comment was received The ODP agrees for the need to training to all stakeholders, including the individuals we serve and their families, and the transition plans have been revised accordingly. The ODP is currently developing a training that will provide an overview of the CMS Final Rule. This is the first training in an ongoing series as ODP begins to move through the transition plan.
and often do not understand the consequences of their actions. Providers (and the individual’s family who are concerned about such situations) should have some mechanism to assist in preventing these situations from occurring. *One similar comment was received Less intrusive methods of meeting the need that has been tried but did not work. A clear description of the condition that is directly proportionate to the specific assessed need. A regular collection and review of data to measure the ongoing effectiveness of the modification. Established time limits for periodic reviews to determine if the modification is still necessary or can be terminated. Periodic reviews to determine if the modification is still necessary or can be terminated. Informed consent of the individual. An assurance that interventions and supports will cause no harm to the individual. The transition plans currently state that a communication will be developed and published regarding required Individual Support Plan documentation when such a modification is needed. 4 Concern that individuals safety is at risk if he or she can lock/unlock unit doors, have unrestricted visitors, have access to food at any time, or can leave the home without necessary supports. *Four other similar comments were received CMS allows modifications to the residential setting requirements referenced in the comment. Modifications must be supported by an assessed need and justified in the person-centered plan. The transition plan currently states that the Department will develop and publish a communication regarding required Individual Support Plan documentation when such a modification is needed. 5 The broadest of accessibility should be used. All of these areas need to be assessed for the specific residents and may require the department to establish different licenses for homes where residents are wheelchair users. If a home has both individuals who are ambulatory and some wheelchair users the higher standard for the home should be used. Regardless of licensing requirements, all residential settings must be physically accessible to the individuals residing there. 6 The Department needs to provide the “lease agreement” to residential providers so there is consistency across the state. The current transition plans state that the room and board contract will be revised to reflect the new requirements and distributed. 7 Any landlord tenant lease must allow for residents and/or provider an avenue to terminate for health and safety issues. To require an individual to remain in an unsafe or unhealthy environment will impact the resident and any roommates possibly jeopardizing As stated in the current transition plan, the Department needs to analyze Pennsylvania’s landlord tenant law and determine what constitutes comparability for residential settings. The Department