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Date ArticleType
8/16/2016 INCAL
HCBS Transition Plan AL Services Summary

A brief summary of the FSSA’s Amended Transition Plan related Assisted Living Services being in compliance with CMS’s Home and Community Based Services rule is linked here. The Plan addresses many HCBS services, but this memo focuses on AL.

Key issues:
(1) Based on the Plan and discussions with the Division of Aging the likelihood that the DA will move away from ISDH Residential Care Facility (RCF) licensure for purposes of AL services on the A&D waiver;
a. We have heard from some of our members that keeping RCF licensure is important, but also from others that not using RCF licensure would be fine if the DA replaces it with some other license or oversight.
(2) AL units that are co-located within a nursing facility are likely not going to be compliant, even with remediation, and will be ineligible for the waiver program; and
a. This is not really a surprise, and while the Plan does not state this outright, it has been stated to me by DA staff. The authorizing Federal regulation prohibits NFs from being HCBS settings, but wings of ALs are regulated as RCFs so there was and still is, somewhat, an open question.
(3) The process for secured memory units within AL is still unsettled.

We need your feedback, particularly on item (1). Comments to the Agency are due August 26th. Please provide us comment by August 19th, send to kniehoff@ihca.org or zcattell@ihca.org

Original FSSA Notice:
The Indiana Family and Social Services Administration (FSSA) is seeking public input on the amended Statewide Transition Plan (STP) that includes site-specific assessment results. The plan will be open for public comment for 30 days, July 27 – August 26, 2016. Visit the Home and Community Bases Service (HCBS) Final Rule Web page for additional details. https://secure.in.gov/fssa/da/4917.htm

This comment period will allow all Home and Community Bases Service members, providers and stakeholders an opportunity to provide input to the plan. Comments and input regarding the amended STP may be submitted in the following ways:

• Email: HCBSrulecomments@fssa.in.gov
• Written comments may be sent to:
State of Indiana
Attn: HCBS Final Rule - Kelly Flynn, Manager, State Plan and Waivers
402 W. Washington St., Rm. W374 MS - 07
Indianapolis, IN 46204-2739