APD budget

megan wall

Megan Wall, esq

Summary of the iBudget Rule Challenge Final Hearing before DOAH

Earlier this month, I attended the three day rule challenge hearing before the Division of Administrative Hearings (“DOAH), at which Holland & Knight attorneys Gigi Rollini, Karen Walker and Matthew Mears represented developmentally disabled consumers challenging the third version of proposed rules to implement the iBudget.  Like so many other consumers receiving services through Florida’s Developmentally Disability Services Waiver, all four Petitioners received significant proposed reductions under the iBudget further depleting their already inadequate funding.  Because this case impacts every Waiver consumer, I am summarizing what occurred for those who could not attend.

In response to the rule challenge, APD hired five private attorneys, in addition to two in-house lawyers. The team of seven lawyers had significant resources at their disposal to defend the rule.

In Florida, rule challenges are fast track cases meant to be heard within 30 days from the filing of the petition.  This hearing was scheduled the very first full week in July. The Holland & Knight lawyers fought hard (and succeeded) against APD’s attempts to delay the hearing. While it is difficult to go to a full-scale hearing so quickly, the Holland & Knight team was concerned that to give APD more time to prepare would drive up the expense of the case. Amazingly, despite the holiday weekend, the hearing began as originally scheduled, which was difficult but strategically important.

The case at its core is simple. The iBudget statute directs APD to set each client’s funding for services at an amount based on a statistically valid algorithm, and then consider if the person needs an increase to that amount because of extraordinary, one-time, temporary or changed needs.  Florida law prohibits APD from enacting rules that run contrary to, or expand the implementing statute. Despite these legal limitations, the evidence in the case showed that:

1.         APD used the algorithm only as a starting point for setting funding because, in APD’s own words, the algorithm APD designed produced “harsh results” for many. Because the algorithm does not result in an equitable allocation of the funds for DD waiver clients, APD created an elaborate and subjective “methodology” to decide whether or not to use the algorithm to set a client’s iBudget. This supplemental “methodology” treats some groups of people differently, even where clients in those groups have the exact same needs.  Most glaringly, APD’s “methodology” targets existing DD waiver clients and singles them out to receive lower budgets than a new client with identical needs. Given that the law requires an “equitable allocation” of funds based on “the client’s level of need,” the evidence showed at the hearing that APD’s actual system is not consistent with the system described in the iBudget statute.

2,         APD told the Florida Legislature that if it adopted an iBudget system for Florida, then 64% of existing Waiver clients would see an increase in their budgets as a result of the iBudget.   However, APD later made a “policy decision” that funding increases simply would not be given and the algorithm would be used only to reduce, not increase a client’s allocation of funds.

3.         Former University of Florida Professor Dr. McClave (an expert in statistics and econometrics who has written text books on these types of models and created successful Florida Medicaid models) reviewed and tested the APD algorithm and testified on behalf of the Petitioners that it was statistically unreliable, including that APD’s chosen algorithm had a margin of error of over 40%!  He said that this is not a model based on a valid statistics approach, and that the model was unacceptable in his field. He memorably testified that APD’s chosen model is as accurate as “throwing darts at a wall of numbers.”

4.         APD identified no specific legal authority that allowed it to implement the iBudget the way it is being done. APD could point to no legal authority to use a statistically unreliable algorithm, to reduce amounts determined by the algorithm, to use a “decision tree” process to reduce existing client’s budgets, to single out existing clients and assign them lower budgets, or to reduce budgets without any final rules at all.  Recognizing the shortcomings of its own position, APD admitted it asked the Florida Legislature in 2012 to change the iBudget statute to  conform to how APD was actually implementing the program.  The Legislature declined to make the revisions. Regardless, APD simply continued to implement the system using its system rather than one consistent with the statute.

5.         APD’s statistics expert (Dr. Niu), who designed the algorithm, testified that he did what his client (APD) asked him to do and he did his best.  He did not consider other state’s algorithms. His reason was that he did not need to because he “only relies on [him]self.”  He used a very few variables (about seven), and assumed he could drop out some variables (such as the entire physical status portion of the QSI) on the basis that other, similar variables (such as the behavioral status portion of the QSI) tended to measure about the same thing—not realizing that every DD client doesn’t have both physical and behavioral needs, or does not have them in equal force. The result—those with significant physical needs, but no significant behavioral needs, will get substantially lower budgets than those with equally costly behavioral needs.

Also, it was shocking to learn that Dr. Niu “meant to do testing” to ensure the validity of the model, but then just did not get around to performing the type of testing necessary to ensure the validity of the model.  He did no testing against other years’ budgets (as is commonly done in statistics, apparently), or “log” method testing (as is typically done in statistics, apparently, when the model is a budget allocation or distribution model).  This was the case even though Dr. Niu has done a much simpler distribution model for the Florida Department of Transportation, and he did do “log” method testing for that model.

Dr. Niu also had no response to the UF Professor’s testimony that the algorithm was not statistically valid.  In fact, he said complimentary things about the other expert, Dr. McClave, and hoped his model “would get better over time.”

NoteAPD testified that it will analyze each client’s iBudget every 12 months to determine what further cuts can be made.  When APD decides it is appropriate, it may (or may not) re-run the inaccurate algorithm in any year it wants.  Under the proposed rules, APD has authority to use the proposed subjective methods in the rule to further reduce client services at its discretion. However, for future years, the processes which permit increases for extraordinary, one-time, temporary and changed needs will no longer be available to the person whose services are being reduced.  Of course, if the algorithm dictates an increase for a DD client, APD will still have the ability to find that award is “really just not medically necessary,” since APD continues to be the sole determiner of what is and what is not medically necessary.

APD’s arguments in response to Petitioners’ case were as follows: We worked really hard on this system; the Tier system has expired and, if this new system is thrown out, APD cannot return to the Tier system; we did our best; we do have authority to do what we did (without specific reference to any law or statute); and, mainly, the Florida Legislature is very happy with APD because APD has substantially cut the cost of the DD waiver program with APD’s interpretation of the iBudget system!  In fact, APD testified that the Legislature “rewarded” APD as a “thank you” for doing such a good job with two additional appropriations totaling $60 million, which APD used internally and to bring people off the waitlist.  [The judge asked if APD should have put that into the iBudget calculations and reappropriated the money to the existing DD clients, and APD said no; the Judge asked if APD had re-run the algorithm since APD first did it (one time) based upon each years’ new appropriation, and APD said, “No, and we are not going to.”]

And, finally, there was the real client example offered at the hearing: An amazing and articulate father of a DD 26-year-old came in and told his son’s story—with a 20 IQ, he lives in a home inherited by his father, which permits his son and two other DD clients to have extremely reduced rent.  All need 24-hour supervision, which they can barely piece together between the three of them—with less and less money each year, less and less of a rate of payment each year.  And, now, all three have been given iBudget reduction notices (his son’s, alone, is an over $8,000 reduction under iBudget).  They were barely making it since their budget is already to the bone (even with the father’s substantial assistance). With the cuts now proposed, there is no hope and nowhere for them to live, except an institution were these cuts to be implemented.

With that, the story of this proposed iBudget system was told.  The agency admitted it was not following the statute to implement the system and the model being used cannot be shown to be statistically reliable.  They agreed that cuts may continue each year. Even if every client could bring into an individual hearing an expert statistician to object to algorithm used to calculate the proposed reduction, the DCF Fair Hearing Officers lack the authority to find the rules invalid. Only DOAH has that authority.  Thus, the reason why this case is before DOAH for a decision, and why it is so crucial a test case.

A decision will be issued around the end of August or early September.  The lawyers for the Petitioners agreed to file this case without sufficient cash in hand on the hope that once the DD community knew the truth about the proposed iBudget system, they would join together to support efforts to compel APD to use an algorithm that is statistically reliable  and a process that follows the law. The Petitioners’ lawyers brought this David and Goliath case, did it in an unbelievably short period of time and, as a result, kept the costs to a bare minimum ($225,000).  Our team, led by Gigi Rollini, presented a clear, articulate, and persuasive case.  And, now, we have to pay her!  [And did I mention that in addition to APD’s seven attorneys and the work they all created, there was also surprise evidence sent by APD at 8:30 am the final day of trial, and surprise witnesses on the final day of witness disclosure—less than one week before hearing—including an expert APD brought in at the last minute and paid $85,000 for his service. And despite the additional work and expense tied to this surprise witness, he ultimately did not even testify because he had nothing to say after hearing Dr. McClave.]

Please contribute now to help us to meet our $125,000 goal!  To get there, we are asking that you consider donating at least at the $10,000 level.  We also specially thank those increasing this to the $20,000 level—we could not do this without you!

Please be a part of the solution!  There are two easy ways to contribute to the APD iBudget Proposed Rule Challenge:

(1)       Checks may be made out to Holland & Knight LLP, and sent to ATTN:  Gigi Rollini, Post Office Drawer 810, Tallahassee, Florida32302; or

(2)          Payment by wire transfer to:

Wells Fargo Bank N.A.

420 Montgomery Street

San Francisco, CA 94104-1207

ABA # 121000248

Account # 2090002390441

For Credit to: Holland & Knight, LLP

Please indicate “APD iBudget Proposed Rule Challenge” as the Beneficiary Reference in the wire.

Thank you!

–Megan Wall, Managing Attorney, St. Johns County Legal Aid

Thanks to guest columnist and Executive Director of Special Gathering, Richard Stimson for this article

Many people within the mentally challenged community are receiving phone calls about the iBudgets.  This is a new thing from the Agency for Persons with Disabilities (APD).

One of the major differences is that APD may ask you to give up some money.  Perhaps they want you to give up $3,000 from your home-care services for which they will pay.  Under the iBudget, you can say back to them, “What about $1,000?  What if you give me $1,000, instead of $3,000?”  Then you must wait to see what APD says.

APD calls this a negotiation.  You will still be able to appeal; but APD is hoping they can find an amount you can agree to give up through these negotiation.  If you ask for an appeal, it will mean that you might win your appeal and you will get everything for which you have asked.  However, if you lose, then you will get nothing.

I have been to two of these negotiations.  These meetings feel like buying a car.  When you want to purchase a car, once you get a price from the sales person, you can ask for a lower price.  Then the sales person has to go and get their boss to sign off on the amount.

I really do not have any good advice.  If you just say, “No,” to the cuts and decide to appeal them it is all or nothing.  You may want to negotiate with APD and try to get something rather than chance getting nothing.

Notice of APD iBudget Workshop Hearing

Agency for Persons with Disabilities
65G-4.020: iBudget Florida

The The Agency For Persons with Disabilities announces a workshop to which all persons are invited.

DATE AND TIME: April 3, 2012, 2:00 PM-4:00 PM
PLACE: Agency for Persons with Disabilities
4030 Esplanade Way Suite 301

Tallahassee, Florida 32399

GENERAL SUBJECT MATTER TO BE CONSIDERED: Implementation of iBudget Florida.
A copy of the agenda may be obtained by contacting: The agenda and any other materials will be posted on the Agency website: http://apd.myflorida.com/ibudget/meetings-and-schedules/.

For more information, you may contact: Kathy Palmer
Agency for Persons with Disabilities 4030 Esplanade Way
Tallahassee, Florida 32399 (850)488-4877

The complete statewide schedule for iBudget Florida implementation is as follows:


4/1/12 – Final component implemented for customers in areas 1 and 2, except Consumer-Directed Care Plus (CDC+) participants. Read more…
7/1/12 – Full implementation for all customers* in areas 4, 12, and 13 and for CDC+ participants in areas 1 & 2.
10/1/12 – Full implementation for all customers* in areas 14 and 23 (Suncoast Area).
1/1/13 – Full implementation for all customers* in areas 3 and 7.
4/1/13 – Full implementation for all customers* in areas 8, 9, and 15.
7/1/13 – Full implementation for all customers* in areas 10 and 11.


APD Residential Fee Collection


On April 1, 2012, the Agency for Persons with Disabilities Residential Fee Collection Rule will be fully implemented State-wide. Attached below, please find four documents which you will need in order to implement this new policy. Please review them carefully . They are as follows: (1) The official notice regarding the residential fee collection initiative (with time frames/requirements), (2) A list of frequently asked questions (along with responses to those questions), (3) A fee calculation worksheet that may be completed by the representative payees, and (4) A copy of the rule notice.


1.   65G-2.016 Residential Fee Collection


2.  Residential Fee Collection FAQs


3.  Residential Fee Collection Notice


4.  Residential Fee Collection Work Sheet


APD Continues Cost Containment Efforts

On April 1, Agency for Persons with Disabilities (APD) will reduce the rates it pays for therapy assessments and all nursing services to the standard rate paid by the Medicaid State Plan.  Currently, the APD Home and Community-Based Services Medicaid waiver pays higher rates for most of these services.
This rate change is the latest cost containment effort by APD to work toward bringing waiver expenses closer to the agency’s Legislative appropriation for the waiver.


Each year in Florida, there are threats of budget cuts to the services of people who are mentally challenged.  More and more, these cuts are a reality.  These are lean times everywhere.  Many states are broke or going broke.

While it appears that other budget items either stay the same or they are increased, the intellectually disabled community received the projected cuts.  Placing blame does little good.  However, we have learned that being proactive does help, especially if the advocacy is done by self-advocates.

Last year, a group of self-advocates traveled several times during the legislative session to petition the legislators to stop the proposed changes and cuts.  While walking the halls of the Senate office building, these men and women “bumped into” the president of the Senate.  They asked for an appointment to speak with him and got one.  Some are saying their advocacy made the difference in legislation being altered in the favor of the consumer.

Last evening, several people who are involved in Special Gathering from a couple of states met for dinner.  One of the SpG volunteers also heads an agency.  “We only get paid for three days of rehab now for Jill and others.  Therefore, we have to be pretty creative with the days for which we are paid.  The other days have to be even more creative,” she said, laughing.  However, I have seen the toll this financial strain has taken on the agency and their employees.

This agency is determined to not enter a “survival mode” mentality.  However, other agencies who work with our population have had to simply find ways to exist.   The uncertainty of funding does play on the minds of people who are mentally challenged.  They are aware of the pending difficulties.

In dealing with our members, it may be good to give them continual reassurance that God has a plan and that He will protect us if we remain faithful to Him.  This will be reinforced and believed, if we truly believe that our stability doesn’t come from the government or even the value of the dollar but from a gracious God who loves us.

For your information:  This is a memo from Cathy Beldell, Deputy General Counsel for APD regarding justification of cost reductions in res hab.  

From:  Cathy Bedell/APD/DCF
To:  10/18/2011 04:56 Gerald Siebens/APD/DCF@DCF, Zaynab  PM Salman/APD/DCF@DCF, Llamilys Bello/APD/DCF@DCF, Tomea Sippio-Smith/APD/DCF@DCF, Melinda Powers/APD/DCF@DCF, Angela Green/APD/DCF@DCF, Melissa  Dinwoodie/APD/DCF@DCF
> cc Jamie Morrow/APD/DCF@DCF, Denise  Arnold/APD/DCF@DCF
Subject  Re cost plan reviews of res hab services

In response to the question posed at our Monday meeting about the reduction of res hab services as part of the cost plan review, the following is my understanding of what is required.
If a reduction to res hab IB or BF is recommended, that decision should be supported and reviewed by the area behavior analyst. It should also be supported by the support plan or progress notes.

If the reduction is related to other res hab levels,i.e., extensive 1 or minimal, the area staff can make that decision based on facility reports or the support plan. This is especially true where res hab may have been adjusted upward for a temporary condition–recent surgery or increase in behavior incidents– and never reduced, as well as where the behavior or condition that supported the original placement has diminished or no longer exists.
> Catherine Bedell
> Deputy General Counsel
> Agency for Persons with Disabilities
> 4030 Esplanade Way; Suite 380
> Tallahassee, FL 32399-0950
> Phone: 850.414.0139
> Fax: 850.410.0665
> Toll Free: 1.866.273.2273
> E-mail: cathy_bedell@apd.state.fl.us

This is information from waiverprovider.com.  Thanks to Florida Unites and Aaron Nangle  for providing this important information.

APD Announces A Schedule of Cuts

            Agency for Persons with Disabilities (APD)

      Director Mike Hansen presented an update on the agency’s cost-containment efforts today to the House of Representatives Health Care Appropriations Subcommittee.

The Legislature approved $810 million for APD’s Medicaid waiver for the 2011-12 state fiscal year that began on July 1. APD customers received $930 million worth of services last year.

The agency has been working to bring its waiver expenditures within the Legislative appropriation this fiscal year. The agency is also looking for opportunities to increase waiver flexibility and equity for customers, while continuing to protect their health and safety.

Earlier this month, APD shared five cost containment initiatives with various legislative committees that would reduce APD’s waiver obligations. The director was asked to bring back a proposed timeline for implementing the changes.

The timeframes may be contingent on developing new rules or federal approval from the Centers for Medicare and Medicaid Services (CMS).

At today’s meeting, Hansen announced plans to standardize payment rates for intensive behavior residential habilitation beginning January 1, 2012. Also on that same date, the agency will begin collecting fees from APD customers who have income to offset some of their costs of living in a group home.

APD plans to reduce the rates it pays for therapy assessments and all nursing services to the standard rate paid by the Medicaid State Plan beginning April 1, 2012.  Currently, the APD Medicaid waiver pays higher rates for most of these services.

Also on the same date, APD will reduce the difference it pays between solo providers and agencies for waiver services to no more than 20 percent. Currently, those rates may differ up to 43 percent.

There was no timeline announced today for implementing cost sharing for parents who have children on the Medicaid waiver. APD is working with the Agency for Health Care Administration on this issue.

The change to the waiver requires federal approval.

After pursuing these cost-containment initiatives to APD’s Medicaid waiver, the agency expects to realize more than $14 million in reduced expenditures on an annual basis. 

For the APD document, click on the link below

Cost-Containment Plan Fiscal Year 2011-2012

This is a comment to the entry, APD Changes.  This gives some clarification and slightly different point of view.  Thanks for your comment.

I have received this email as published at APD Changes also. I would also look at the descriptors. Your support coordinator can give you a copy.

I do know that the agency that operates the group home where my brother lives has had clients Res Hab reviewed. (This includes minimal level clients which means the possibility of clients being bumped down to basic level.) The email you posted did not have that rate for basic level but I think it is someting like 1,100 dollars.

I have heard that it is APD’s view that the organization APD had contracted with to approve services (and the level of those services) had been approving services incorrectly. APD no longer contracts with that agency and is approving services on there own (I think).

It appears from the email you posted that group home clients are being warned to review their support plans to make sure the support plan justifies the level of Res Hab. There appears to be an assumption that there is a problem with the way support plans are written.

I do not understand the line, “but the judge will only be looking at what was actually submitted. You will not be allowed to give the judge more documentation during your hearing”

If the problem is a support plan that was written incorrectly by a support coordinator and wrongly approved, why can’t a client inter new information that shows they need the service? It does make you wonder about the recent requirement on insurance (a long standing requirement that was never inforced). Will support coordinators become responcible for the loss services because of poorly written support plans?

One other thing. I wonder why the email you posted (unless I missed it) does not include supervision of self administration of medication under minimal Res Hab (the copy of the descriptors I have list that). In that every group home I know of administers the medication I would think this requirement would be met.

This is the current newsletter sent by WaiverProvider.com. I am unable to format this correctly. To see the entire newsletter, go to the websight.

WaiverProvider.Com September 30, 2011

Is Your Support Plan Current And Correct?

All cost plans are being reviewed between now and November 15, 2011. If your need for services are not well documented, they could be eliminated or reduced. It’s very important that all documentation be sent up at the time of review. If your services are reduced or eliminated, you will have a chance for due process, but the judge will only be looking at what was actually submitted. You will not be allowed to give the judge more documentation during your hearing. Contact your support coordinator to learn more.

Minor Differences, That Are Not So Minor

Is Justification For Your Residential Habitation Rate Documented?


$2195.48 Month


$3294.48 Month

Self care/daily living tasks:

including physical assistance and mealtime intervention to eat safely, may require mealtime interventions and/or devices.

May require consistent verbal and physical help to complete self care/daily living tasks,

Requires substantial prompting and/or physical assistance to perform self-care/daily living activities.

May be totally dependent on staff for dressing/bathing. May require mealtime interventions and/or devices OR receives all nutrition through a gastrostomy or jejunostomy tube.


May require scheduled toileting or use of incontinent briefs.

Incontinent of bowel or bladder. May require scheduled toileting or use of incontinent briefs.


Walks independently or independently uses a manual or power wheelchair.

Independently uses a powered wheelchair, may need assistance with a manual chair.

Transfer / Change Positions

· May require assistance to change positions.

· Needs physical assistance of one person to transfer or to change positions.

· May require assistance to change positions.

· Needs physical assistance of one person to transfer or to change position.

· Disability prevents sitting in an upright position, has limited positioning options.


· May exhibit behaviors that require formal and informal intervention;

· requires frequent prompts, instruction or redirection, some environmental modifications or restrictions on movement may be necessary.

· May exhibit behaviors that require frequent planned, informal and formal interventions.

· Assistance from others may be necessary to redirect the recipient. May require psychotropic medication for control of behavior. Self-injury or aggression towards others or property results in broken skin, major bruising/swelling or significant tissue damage requiring physician/nurse attention. May have threatened suicide in past 12 months. May have required use of reactive strategies 5 or more times per month in last 12 months. May routinely wear protective equipment to prevent injury from self-abusive behavior.


· Seizures: If has seizures, no interference with functional activities;

· May require medication for bowel elimination.

· May require a special diet. May require staff supervision to self-administer medications.

· Seizures: May have seizures that interfere with functional activities; receives 2 or more medications to control seizures.

· May require medication and daily management, including enemas, for bowel elimination.

· May be nutritionally at risk and require a physician/dietitian prescribed special diet.

· May have experienced a pressure sore requiring medical attention in the past 6 months.

See All Provider Rates

(888) 444-3331



*Information in our newsletters is provided by Clear Choice Web Solutions, Inc. which is not controlled or monitored by The Agency For Persons With Disabilities. The information provided in our newsletters has been submitted by support coordinators, waiver providers, and family members. Research has been done by Clear Choice Web Solutions. Inc. staff. We do our best to provide you with up to date and accurate information, however, always check with The Agency For Persons With Disabilities. You can call their Toll Free Number 1-866-APD-CARES or 1-866-273-2273 .

2011 All Rights Reservered | WaiverProvider.Com | 1.727.5841.8943

Email received outlines a DRAFT plan of PROPOSED Waiver reductions for people with developmental disabilities.  Because the format of this informational sheet is not compatible with the Weblog and my formatting abilities are extremely limited on the blog, I am reformatting it so that it will fit properly.  There is no website that you can be linked to that contains this information.

1.  Companion ration/limit adjustment–expected savings $18,605,801 

  •  Detailed Description–Allow up to 3 people to be served/Set rate at average of the 1:2 level
  • Action Needed–Handbook change, rate rule change
  • To be completed as of August 1, 2011

2.  Allow IHSS in all tiers in the family home as a less costly option for PCS at lower IHSS rate–expected savings $1,765,277

  • Detailed Description–PCA at 15 per hour versus IHSS at 12 per hour–optional to help reduce cost of services and must always be considered for an increase of services
  • Action Needed–Case Review
  • Started July 1, 2011 with case by case review

3.  Transportation Review and service limitations–expected savings $1,375,000

  • Detailed Description–Ensure transit is funded by waiver only as a last resort and limited number of round trips
  • Action Needed–This requires a county-by county review to ensure cost effectiveness.
  • Reviews to be completed in September 2011 with service limitations effective November 1, 2011. Areas are working with Transportation Disadvantaged Providers to achieve most cost-effective delivery of service.

4.  Pool Respite services for families to draw from and reduce allocation–expected savings $975,042

  • Detailed Description–This initiative primarily reduces unused service authorizations in current cost plans. The actual savings are based on 3% reduction in actual billings with 10 months implementation
  • Action Needed–Currently being implemented and will be completed by October 1, 2011

5.  Move SMH Therapy to MSP (adults)–expected savings $1,395,703

  • Detailed Description–JT to DCF move expenditure from waiver through amendment for the long term because service is provided by DCF/ACHA
  • Action Needed–Handbook change, Rate Rule change, Waiver Amendment
  • While waiting for waiver amendment, case by case transition of services to MSP. Waiver will be amended this FY

6.  Move skilled nursing to MSP (adults)–expected savings $1,615,650

  • Detailed Description–JT from AHCA and remove expenditure from waiver and do waiver amendment for the long term because skilled nursing is provided by MSP
  • Action Needed–Handbook change, Rate Rule change, Waiver Amendment
  • While waiting for waiver amendment, case by case transition of services to MSP. Waiver will be amended this FY

7.  Rate adjustment for all ADT recipients and reduce burdensome regulations–expected savings TBD

  • Detailed Description–Rate adjustment to targeted savings
  • Action Needed–Handbook change, Rate Rule change with reduced paperwork and regulation
  • Prior proposed to consolidate into one ADT rate not well received. Seeking provider input for alternative savings in this category

8.  Eliminate Behavior assistant services with ResHab and ADT–expected savings ?$5,000,000

  • Detailed Description–Elimination of duplicative services occurring in the same settings
  • Action Needed–Handbook change for policy clarification
  • Behavior Assistance services are duplicative of the services and training provided in residential habilitation and adult day training

9.  Agency Rate premium set to a maximum of 20% above solo rates for all services with agency rate–expected savings $3,712,169

  • Detailed Description–Currently there is a range of 5% to 45% over solo rates as an agency premium 
  • Action Needed–Rate Rule change 
  • Current rate premiums vary from 5% to 42% depending on the service category

10.  Behavior Analyst collapse rate from level 1 to level 2–expected saving $2,580,874

  • Detailed Description–Rate for level 2 is $50 per hour for solo and agency is 20% above – based on average
  • Action Needed–Handbook change, Rate Rule change
  • Current behavior analyst rates for level 1 are not directly associated with the client level of need or service outcomes and are based solely on years of experience

11.  Rates reduced to MSP (nursing and therapies and assessments)–expected savings $1,530,476

  • Detailed Description–Use current waiver rate X units – MSP rate X units
  • Action Needed–Rate Rule change
  • Currently in process of including this change in the DD Rate Rule

12.  Res Hab reduce rate levels from 9 to 4–expected savings $21,113087

  • Detailed Description–redefine level of support descriptions and associated rates and revise associated staffing levels in the handbook
  • Action Needed–Handbook change, Rate Rule change
  • Seeking provider input for alternative savings in this category

13.  IHSS collapse quarter-hour above live-in rate–expected savings $2,914,937

  • Detailed Description–Delete use of quarter-hour above the day rate
  • Action Needed–Using QSI 1,2,3 and eliminate IHSS 1/4 hr above day rate
  • Individuals with level of need 1,2,and 3 do not require additional supports beyond a daily rate for in-home supports

14.  Utilization management of behavioral services–expected saving  ?$3,000,000

  • Detailed Description–6 month increment with reapplication and approval required after each increment:  declining hours based on matrix scores
  • Action Needed–none
  • Implementing on-site reviews for continued stay in intensive behavioral programs. Additional utilization reviews ongoing to match services to level of need of client

15.  Publish Standardized 1B rates for future with lower rates retained–expected savings $1,549,764

  • Detailed Description–Standardizing rates based on individual needs rather than negotiated contract
  • Action Needed–Rate Rule promulgation required
  • Rate Matrix in development.  Savings dependent on effective date

16.  Res Hab quarter-hour eliminate since other options are available for in-home supports–expected savings $917,290

  • Detailed Description–Eliminates the quarter-hour unit for this service. Typically used for individuals in their own home and the services is more appropriately provided as in-home support
  • Action Needed–Rate Rule change
  • This would increase IHSS use and reduce service array

17.  Fee collection by residential providers–expected savings *FARF estimate $8,401,147

  • Detailed Description–Create form to calculate recipient responsibility to be deducted from waiver service bills, monthly surplus frozen or swept by service
  • Action Needed–Develop method and procedures to monitor
  • Inplementation strategy and monitoring procedures need to be developed and vetted, late year implementation

18.  12.5% reqd match as state share–expected savings TBD

  • Detailed Description–Would leverage current spending to decrease GR effort
  • Action Needed–Lond term research with AHCA and CMMS
  • Unknown if loca effort is applicable to matching in this context. Variables include in-kind share, local funds, and other sources

19.  Core service models–expected savings TBD

  • Detailed Description–Limit waiver services to only those services considered core to prevent institutionalization
  • Action Needed–Waiver amendment required

20.  Services limits–expected savings TBD

  • Detailed Description–Reduce services limits for each waiver service
  • Services limited to only essential elements within budget

21.  Limit individual cost plan to not greater than average ICF/DD–expected savings $3,300,000

  • Detailed Description–FL ARC estimates 3.3 m based on “limiting most cost plans to $150,000.”
  • Action needed–Waiver amendment required prior to implementation
  • CMMS will require alternative supports for adversely impacted clients.  Data suggest that 17 m in savings could be realized if waivers were limited to individual’s cost of ICF/DD service

History of APD Medicaid Waiver Cuts:

The DD System Needs Stability

  • ·         In July 2003, the State of Floridaadopted the Mercer Rate system that contained up to 720 billing options for residential habilitation rates and new rates for most of the 30+ services funded by the Home and Community Based Services Waiver.  Transportation, Special Medical Homes and Intensive Behavior services continued to have negotiated rates.  The legislature basically bought a reimbursement system that was based on direct care wages funded at the 25th percentile compared to national averages for wages.
  • ·         In November 2003, the Agency reduced Residential Habilitation rates by 14.3% and Live In Residential Habilitation by 7%.  Also, billable days were limited to 350 per year for homes having more than 3 individuals.  ADT rates were reduced by about 9.5%.  The actions were taken to prevent deficit spending although the state actually realized a surplus at the end of the fiscal year.  The annualized reductions totaled about $45 million for three services.  According to Medicaid claims data, the Agency realized a $37 million surplus for the same year.
  • ·         In 2004, the Agency implemented a residential habilitation matrix approach which limited billings by looking more at the number of hours needed per home to adequately staff it.  The impact was significant in that in many cases the last two admissions to a six-bed group home received reduced hours (typically 2). 
  • ·         In 2006, agencies received a 2.81% Cost of Living Adjustment that applied to all waiver services.   This action added about $21 million back into the system.
  • ·         During the 2007 Legislative Session, the Florida Legislature mandated changes in Senate Bill 1124 that resulted in limitations and eliminations of Developmental Services Home and Community Based Services (HCBS) Waiver services funded through the Medicaid program.   Although implemented, the limitations and eliminations have resulted in little if any savings in waiver expenditures because clients often shifted to other services to meet their needs.

–     Chore, Non-residential Support Services, and Homemaker Services were eliminated for a projected $12.7 million savings to APD.  However, the definition of In-Home Support Services has been expanded to include some activities previously provided in the eliminated services.

–     Massage Therapy and IQ Testing (Psychological Assessments) services were eliminated for a projected $2.2 million savings to APD.

–     APD will be implementing a uniform rate for individuals with intense needs for and estimated $1.3 million savings, but a date for implementation has yet to be set.

–     Supported Living Coaching has been limited to no more than 20 hours a month for persons who also receive in-home support services for a $4.4 million savings.

–     Support Coordination to all persons under the age of 18 who live in the family home are limited to Limited Support Coordination only for a $1.7 million savings to APD.

–     Personal Care Assistance (PCA) services have been limited to 180 hours a month unless the person has intensive needs and all rate modifiers have been eliminated. Additional hours may be authorized if there is a substantial change in circumstances.  Projected savings were at $2.3 million.  APD and AHCA have reached an agreement which allows for people under the age of 21 to receive more than 180 hours of PCA, if medically necessary. TheMedicaidStateplan is to cover the cost of the additional hours.

  • ·         In December 2007, residential habilitation rates were collapsed and reduced overall by 7%; however, a settlement agreement reduced the reductions to 4.25%.  Some providers actually realized increases because of an averaging effect.  The net savings was about $11 million.
  • ·         As a result of the 2007 legislation, AHCA in consultation with APD sought and obtained federal approval for two additional waivers to implement a four-tiered waiver system. The tiers were implemented in the fall of 2008 and were intended to remove $120 million from expenditures in the waiver system.  However, due to rate reductions and other changes the annualized savings will be about $74 million per year.  

–     Tier 1 – Current DD Waiver with No Monetary Cap: Limited to individuals with intensive medical, behavioral, and adaptive needs that cannot be met in other tiers.  

–     Tier 2 – Capped at $55,000: Limited to clients whose service needs include support in a licensed residential facility and at least minimal moderate levels of residential habilitation with behavior focus services as well as clients in supported living who receive more than six hours of in-home support services. This tier applies only to individuals who receive residential habilitation or supported living and in-home support services.

–     Tier 3 – Capped at $35,000: Includes all individuals who do not fall into Tier 1 or Tier 2.

–     Tier 4 – Current FSL Waiver with a Cap of $14,792: Includes most families with children under 21 who are to receive Personal Care Assistance services via the Medicaid State Plan.

  • ·         In May 2008, proviso language passed that implemented a $43 million across the board rate cut for waiver services that was implemented in July 1, 2008.  Residential Habilitation and Support Coordination received a 3% cut effective July 1, 2008, (in addition to the 4% reduction taken in December 2007 for residential habilitation) and other waiver services received a 7.21% reduction in rates.  Other changes included:

–       In May 2008, legislation passed reducing the rate paid to Personal Care Assistants by four percent.

–       Support coordinator’s caseloads can increase to 43 people per month, up from 36.  APD will no longer require support coordinators to conduct a customer’s needs assessment or develop their cost plan.  Support coordinators will still be able to earn up to $68,000 a year if they have a full caseload.

–     In July 2008, South Florida providers had geographic rate differentials reduced for residential habilitation services by 2.5% in Broward,Palm Beach, andDadeCounties. MonroeCountyrealized a 5% reduction. 

  • ·         In October 2008, the APD began a rebasing exercise which was intended to freeze individual service expenditures as of January 2009 at the FY 07-08 level plus no more than a 5% increase until June 30, 2009.  Because of inaccurate data, the exercise was delayed until late December.  The intent was to control a projected 9% utilization creep that results in deficit spending.  APD projects saving $20 million per year from this exercise although the methodology used will likely result in higher savings.
  • ·         In January 2009, during a Special Session the Florida Legislature approved a 3% rate reduction ($21 million) for DD waiver services.  However, the rate reduction was vetoed by the Governor and was not implemented.
  • ·         Per the 2009 Legislature, effective October 1, 2009, Medication Administration Review services will be eliminated as a waiver service for a total reduction of $301,907 and effective January 1, 2010, consolidation of durable and consumable medical supply purchases will save another $932,093.  The 2009 legislature did add $5,934,889 to the DD Medicaid Waivers to maintain a geographic differential for residential habilitation service providers in fourSouth Floridacounties.   Also, one-time funding of approximately $19 million was added to maintain service delivery.
  • ·         The 2010 Legislature decreased the overall funding level for the waiver by $43.8 million, and did not continue anticipated federal stimulus (FMAP) dollars that would continue Florida’s current enhanced FMAP ratio from January 2011 through June 30, 2011.  The cuts are as follows:

–       $3,075,000 transfer to the Agency for Health Care Administration (AHCA) to provide disposable incontinence supplies to children ages 4-20 through the Medicaid state plan. 

–       $4,196,362 savings as a result of reducing the caps for Tiers 2, 3, and 4 by 2.5%.  Notices of reductions were sent in December 2010 with an effective date of February 2011.

–       $1,393,145 savings by limiting Tier 1 annual expenditures to $150,000 annually and excluding Intensive Behavior and Special Medical Care homes from the cap effective January 1, 2010.

The proviso language approved by the 2010 legislature included $16,811,989 for a 2.5% provider rate reduction for most waiver services excluding:  Support Coordination, transportation, personal care assistance, durable medical equipment, consumable medicals supplies, and environmental and home accessibility services are specifically excluded from this reduction target.  Governor Crist vetoed the rate cut language but did not reinstate the dollars.  The allocation also included an additional $18,396,571 in cuts that were removed as one-time funding.  These two actions reduced the appropriation by $35,208,560.

While theGeneralRevenue portion of the appropriation actually increased by about $38.9 million, the Trust Fund portion was reduced by $78,790,410. 

The following shows the funding history of the HCBS and FSL Medicaid Waivers since FY 03-04 when the System Redesign was implemented. 


DD Medicaid Waivers Summary

FY Appropriation Expenditures Surplus/Deficit Served Ave. Cost
FY 03-04 $687,255,720 $654,883,720 $32,372,000 24,257   $26,998
FY 04-05 $734,118,671 $644,339,179 $89,779,492 25,848   $24,928
FY 05-06 $798,141,900 $749,150,257 $48,991,643 30,936   $24,216*
FY 06-07 $851,549,572 $905,954,703 -$54,405,131 30,991   $29,233
FY 07-08 $961,599,474 $927,531,579 $34,067,895 30,585   $30,326
FY 08-09 $833,529,770 $882,784,502 -$49,254,732 30,166   $29,264
FY 09-10 $849,699,685 $928,167,201 -$78,467,516 30,275   $30,658
FY 10-11 $805,826,618        

From the above, we see the funding level for FY 10-11 is only about $7 million more than it was in FY 05-06 and the program is now in deficit spending status.  The deficit appears to be attributable to the fact that in FY 05-06, about 5,000 new enrollees were added late in the fiscal year but the total cost of care was not realized until FY 06-07, and this began a history of deficit spending.  In FY 07-08, funding was added to sustain the program for one year until cost control measures could be implemented; however, the anticipated savings have not materialized. 

The above data show about 660 fewer individuals are being served per year than were served in FY 05-06.  Concurrently, thousands of individuals on the waiver are receiving fewer services as a result of tier caps, rebasing, and other cost savings measures.  Also, only limited numbers of new enrollees are being added and these are typically individuals who are in crisis status.

A modest increase in average expenditures per recipient is noted and is considered reasonable (less than 2% per year), especially considering only those who are most in need of services (crisis status) are enrolled and will have higher costs than non-crisis enrollees.  Also, as the annualized cost for the FY 05-06 additional enrollees was realized in FY 06-07, average costs had to increase as shown in the above chart. 

Florida ARF opines the cost of this program is being managed; however, the program simply is not funded at the level needed to serve the number of individuals enrolled.

Florida ARF Summary of DD Waiver Cuts

Prepared: December 2008

Updated May 2009, June 2010, January 2011, March 2011

Subject: Urgent – iBudget assault on providers

August 13, 2011
Dear TheBehaviorAnalyst.com members and friends,
The workshop on the Medwaiver iBudget Handbook on August 9th was a bit of a surprise, there was little or no advanced warning about it.  There are several changes in the handbook, and we strongly suggest that if you are a Medwaiver provider, if you work for a Medwaiver provider, or if you are thinking of becoming a provider, you go to the link and review the manual for yourself.  It is located at: http://ahca.myflorida.com/Medicaid/review/index.shtml, click on the ibudget handbook.
We would also suggest you have others, like your consumer’s advocates, look at it as well.  Feedback must be received by AHCA by 5:00 pm on Tuesday, August 16th.  Please submit feedback by Sunday evening to admin@TheBehaviorAnalyst.com, in order to allow time to consolidate the information. If your agency belongs to Florida ARC or FARF, you may also want to express your concerns to them, or email your comments directly to susan.debeaugrine@ahca.myflorida.com (or fax: 850.414.1721 to Susan’s attention).  Please do not read this and send back a general response saying “I don’t like this”, or something similar.  Read the manual and give specific questions or feedback with page references!  The handbook process should also include a hearing before it is adopted, but keep in mind October is the projected time ibudget will start in the Tallahassee area.  Please forward this email to as many providers as you can, there is not much time to respond.
The changes of greatest concern to behavior analysis providers at this point seem to be:
Changes to the definition of “Agency”, an agency is now defined as: (Page 3-8) “An agency provider is a business or organization enrolled to provide a waiver service(s) that has four or more staff employed to carry out the enrolled service(s).”  Also, contractors are prohibited, staff must be EMPLOYEES.
Providers required to submit service logs shall at a minimum do so via the client central record system as follows; For services that are billed at the daily or quarter hour rate;
Supplies and equipment; and assessments – within 15 calendar days after the date on which services were rendered. For monthly rates – within 15 days after the month ends.  You will not be able to bill until all paperwork is entered into the system. ADTs (and maybe other services) can only bill once a month.  
Training with changes. (Starts on 3-1) Mandatory training for all staff would include:
1. The iBudget Florida waiver program: The iBudget Florida pre-service training will include brief introductions on subjects including; promoting choice, person centered approaches, incident reporting procedures, HIPAA, recognition of abuse, neglect and exploitation, domestic violence and sexual assault, and health and safety responsibilities
2. CPR/ First Aid (CPR must be taught via classroom setting by a trainer certified by either the American Heart Association or the Red Cross. Online CPR training is not acceptable training to meet this requirement)
3. iBudget Florida Coverage and Limitations Handbook
4. HIV/AIDS and infection control
5. Zero Tolerance (must be received by all agency employees prior to providing direct service and shall be completed at least once three years)
6. Medication Administration: Chapter 65G-7, Florida Administrative Code
It is the responsibility of the provider to ensure that training which carries an expiration date (CPR/First Aid, HIV/ AIDS, Infection Control and HIPAA) is received prior to the expiration date to avoid any lapse in certification.
Changes to ADT include: (Page 4-10) 1:3 and 1:1 staffing ratios require that the individual meet criterion for Behavior Focus or Intensive Behavioral ResHab. (From Page C-3) “At all times when individuals are present, a minimum of a least one staff member or 50 percent of all staff at the facility (whichever is greater), must have been trained on Reactive Strategies and Medication Administration.”  
ResHab – (Page 4-47) IBResHab qualifications includes significant behavioral events within the past 6 months.  If a consumer is in a highly prostheticized environment, and they haven’t had a major even in the past six months because of lots of staff pre-crisis intervention, they may lose IB designation.  Also, IB ResHab requires a BCBA Level I as clinical director of the IB program.
Changes to Behavior Analysis – (Page 4-81)There is a lot of wording regarding training caregivers such as “Training for parents, caregivers and staff is also an element of the services to ensure maximum effectiveness of the services and because these persons are integral to the implementation or monitoring of a behavior analysis services plan.”  The problem is, those of us who work with adults may be working with individuals who do not have a caregiver to train.  It is inappropriate to ask the city bus driver or the consumer’s employer to implement a behavior program.  Also, with the high turnover of support staff, training PCAs, Respite Providers, In Home Support Personnel, siblings, ADT staff, etc., we are unable to realistically provide an environment where the staff and primary caregivers are trained.
Changes to Behavior Assistant  – (Page 4-84) These services are now a travesty.  Originally designed to provide a behaviorally-trained paraprofessional to implement behavior programming to individuals with challenging behaviors, they are now defined as: “The primary role of the BAS provider is to assist the Behavior Analyst or provider licensed under Chapter 490 or 491, F.S. in training paid and unpaid caregivers for the service recipient in the consistent and accurate implementation of the BASP and recording of related data. Unlike other services, the BAS provider’s focus is more on working with the caregivers to provide them with the skills to execute the procedures as detailed in the BASP, rather than, the BAS provider intervening directly with the service recipient.”  It goes on to state that the Behavior Assistant can work with consumers for a “brief” period, but then must focus on transferring the intervention to others.  Obviously, this is problematic when one is working with an adult, a family with several other small children, or with elderly parents who may have difficulty implementing a behavior program with an aggressive individual.  Services are limited to 8 hours a day, services for 6 hours or more a day require monthly LRC approval, or as “deemed appropriate” by the LRC.  Assistants are required to have 2 hours of supervision by a certified behavior analyst or 490/491 licensed individual per month.  Supervision is not defined (ie: in the presence of the consumer, privately in-office, etc).  Also, no indication if the supervision is billable for either party.  
Transportation – Fifteen-passenger vans that are not lift-equiped cannot transport more than 10 individuals.
Recoupment – There are draconian recoupment policies for late paperwork for the following services: adult day training, non-residential support services, residential habilitation, supported employment and supported living coaching. (Page 5-3)
Behavior Analysis Documentation:
Copy of claim(s) submitted for payment;
Copy of service log;
Copy of assessment report, when as assessment report has been requested
Quarterly summary of monitoring including who, what, when and where of the monitoring events; or other content as required by the Agency.
Quarterly summary of each quarter of the support plan year. The fourth quarterly summary also serves as the annual report and must include a summary of the previous three quarters  
• Behavior analysis service plan and services provided including graphic display of acquisition and reduction behaviors related to implementation of the behavior analysis service plan, and
• Dated evidence of LRC reviews, approval and recommendations specific to target behaviors and the behavior plan, as required and consistent with 65G-4.010, F.A.C.,
Behavior Assistant Documentation –
1. Copy of claim(s) submitted for payment;
2. Copy of service log;
3. Quarterly summary of monitoring of program implementation including the who, what, when, and where of the monitoring events;
4. Quarterly summary of each quarter of the support plan year. The fourth quarterly summary also serves as the annual report and must include a summary of the previous three quarters
5. Copy of the behavior analysis service plan must be in the recipient’s file prior to claim submission.
5. Monthly data displays;
6. A record of the LRC review of the behavior services plan and data displays must be provided if the targeted reduction behaviors meet the requirements identified in 65G-4.009, F.A.C.; and
7. A record of the LRC review of the behavior services plan and data displays must be provided if more than 65 quarter hours of behavior assistant services are approved daily.
Various Appendices identify the specific training requirements, look them over!
Sorry to be the bearers of bad news, but we encourage you to read the manual carefully and give your input. 

APD has more clarification on   Companion Service Rates 

The Agency for Persons with Disabilities (APD) is adjusting the rates it pays providers of companion service beginning August 1.

The rates have been collapsed into one solo provider rate of $1.68 per quarter hour for serving one or two individuals. Providers serving three individuals will continue to receive $1.39 per quarter hour as they did prior to August 1. There is also an agency and geographic differential rate. To review the new rates, Click or past the link below.

 Companion services involve non-medical care, supervision, and socialization activities. This service provides access to community activities when there are no other unpaid sources of support available. The activities that are provided should result in an individuals increased ability to access services in the future without using paid support. A companion provider may assist individuals in learning to use the library, helping to organize volunteer opportunities for people, and providing assistance with specific tasks such as help with light housekeeping.

The Florida Legislature has mandated that APD bring its Medicaid waiver expenditures within its appropriation. The Legislature approved $810 million for the Home and Community-based Services (HCBS) waiver for the 2011-12 state fiscal year that began on July 1. APD customers received $930 million worth of services during the 2010-11 fiscal year.

 Companion Rate Table as of 08-01-2011

Click here to see the Companion Rate Table


 If you can not see this in HTML format past the link below into your browser to see the Companion rate table.


This is copied from Aaron Nangle’s newsletter waiverprovider.com.  Thanks Aaron for allowing us to reprint this.

APD Announces Rate Changes     

For Companion Services

FROM:  Bryan Vaughan, Acting Director For APD Agency for Persons with Disabilities

Effective August 1, 2011, the reimbursement rate for companion services will no longer depend on the ratio of direct service providers to clients served.  As of August 1, all companion services shall be reimbursed at the basic rate of $1.68 per client regardless of the number of clients served. This rate will still be adjusted according to geographical location and whether the service was provided by an independent provider or agency provider.

Updated rates for companion services are available on the Agency’s website and are attached to this notice. These rate changes are being made pursuant to the Agency for Persons with Disabilities’ authority in section 393.0661(7), Florida Statutes. Section 393.0661(7) authorizes the Agency to adjust rates as necessary to comply with the availability of moneys provided in the General Appropriations Act.

These rate adjustments will be reflected in the cost plan of each client who was authorized to receive companion services at the 1:1 ratio or the 1:3 ratio prior to August 1, 2011.  The rate adjustments do not reduce, modify, or terminate any client’s authorized waiver services. APD will provide new service authorizations to all providers no later than August 5, 2011.   Until such time, this notice will serve as your authorization.

The Agency for Persons with Disabilities appreciates  your service and dedication to individuals with developmental disabilities. If you have any questions regarding this notice, please contact your local Area Office. 


WaiverProvider.com & Florida Unites

So this means solo providers will get paid only $6.72 per hour.  Agency’s will get $8.64 per hour. This is according to APD Central office.Minimum wage for the state of Florida is $7.31 per hour. APD has to find ways to cut or they will not be around next year. A disproportionate amount of the cuts are to providers pay. After all providers just got cut by 4%. People need to speak up. You need to visit your legislators and let them know what you think about all of the cuts. Let them know how this affects you and the people you help. 

Disability Expo 2011 & Family Information Forum


July 30th

Miami-Dade County Fair & Expo
10901 SW 24 St Miami, FL 33165

10:00am to 4:30pm

This event is presented by

WaiverProvider.com / SupportCoordinators.com

With help from

AREA 11 Agency For Persons With Disabilities (APD)

Area 11 Family Care Council (FCC)


This is a free event for all families. You do not need to register to attend the event. Come for all of the help and information. Then stay for the dance, door prizes and fun.

We are pleased to present this opportunity for first hand information from the Agency for Persons with Disabilities. Also updates on current issues and future plans of APD Area 11.

WaiverProvider.com will be telling families about resources to help with internet information. Also with ways to help you speak out about your questions and concerns.

The Family Care Council – FCC area 11 will be helping families with information. FCC area 11 is also excepting new members.

There will be Free refreshments & food during the event. We will also be giving away many FREE door prizes at the event. There will also be a dance for everyone to enjoy.

Don’t be left in the dark.
Come talk to the people that can help you.

The event gives you the opportunity to learn about resources & programs that can help you and your loved ones. Also a opportunity to speak out about your questions and concerns.

Learn more information about Medicaid, Social Security, Voc Rehab, Centers for Independent Living & Transition information, Guardianship and more.

DATE: Saturday, July 30th 2011

10:00 – 11:00 am APD, WaiverProvider.com & FCC area 11 11:00 -12:00 pm Break Out Sessions & Exhibitor Time
12:00 – 1:00 pm A Free Lunch & Exhibitor Time
1:00 – 2:00 pm Break Out Sessions & Exhibitor Time
2:00 – 2:30 pm Closing Remarks

Then at 2:30 – 4:30 pm

A Free Dance with a live DJ taking your requests. There will also be many Free door prizes that will be given away to families.

For information about the event please contact  WaiverProvider.com & SupportCoordinators.com
Aaron Nangle: 727-841-8943 or Email: WaiverInfo@aol.com



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