Senior Service America, Inc. “Changing the Individual Durational

Limit Policy” Webinar

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Senior Service America, Inc. (SSAI)

“Changing the SCSEP Individual Durational Limit

Webinar”

Tuesday, May 21, 2013

2:00 – 4:00 p.m. EDT

Webinar Details

Today’s Presenters: Chris Garland & Kamal Elharam

Webinar Length: 2 hours from 2:00 – 4:00 p.m. Eastern Daylight Time

We may finish early if not all time is needed

Agenda

Welcome Change in Policy – Why? Next Steps

Responsibilities of Subgrantees through September 30th

Responsibilities of Subgrantees after September 30th

Important SSAI Dates Between Now and August 31, 2013

Summary Adjourn

How Did We Get Here?

Older Americans Act Amendments of 2006 set a lifetime cap on SCSEP for first time in program’s 40+ year history

Four year lifetime participation clock started for participants on or enrolled as of July 1, 2007 and after

First exits for participants who reached their Individual Durational Limit (IDL) of 4 years occurred July 1, 2011

SSAI’s Current IDL Policy

SSAI did and still does not believe that SCSEP should have a lifetime cap on participation. In our view, limiting every SCSEP participant to a maximum of four years of participation neither reflects a person-centered approach nor recognizes that persons can continue to benefit from longer SCSEP participation. 

Therefore, our policy has been to grant a waiver to any participant who meets the “waiver factors” allowable in the law and regulations to give the participant more time to benefit from SCSEP services.

Why is SSAI Changing its Policy?

1. The decline in SCSEP funding since 2010 has led to longer wait lists. We hope that changing our waiver policy will increase your capacity to enroll new participants.

2. We recognize that the need for SCSEP is greater than the funding Congress provides so we want to facilitate our subgrantees being able to serve people who have not already benefitted from SCSEP.

Questions?

Raise Your Hand to Confer by Phone or Send Us a

Note

What Happens tomorrow, Wednesday,

May 22, 2013?SSAI is sending its notification

letter to participants (with a cc to the Project Director) informing the participant of the change in SSAI’s Individual Durational Limit Policy

If you haven’t sent your letter to participants yet, please do ASAP

Let’s Review the Letter

Project Directors will be copied on the letter

This means if you have 100 active participants, you will receive 100 letters (one letter for each active participant on your program)

If a letter is returned to SSAI due to a bad address, then SSAI staff will call you to:

(a) ask you to mail a copy of the participant’s letter to the participant; and

(b) update the participant’s address in SPARQ

Your Participants Are Going to Fall Into One of Four Categories

(A-D)Category A: Participant currently has a waiver (approved by SSAI) that has extended their time on SCSEP beyond four years and the participant’s waiver expires before or on Monday, September 30, 2013

Example: Participant Garland received a waiver for being age 77 on August 15, 2012 and this waiver will expire on August 15, 2013. Under the change in policy, Participant Garland is eligible for one more waiver renewal. Once her waiver is renewed, Participant Garland’s new four year durational limit exit date will be August 15, 2014.

Category B

Category B: Participant is reaching his/her four-year durational limit for the first time (never has had a waiver before) before or on Monday, September 30, 2013

Example: Participant Ames has not had a waiver but her individual durational limit date is September 15, 2013, and she is eligible for a waiver for Limited English Proficiency (LEP). Under the change in policy, Participant Ames is eligible to receive a waiver for LEP. With this waiver, Participant Ames’ new four year durational limit exit date will be September 15, 2014.

Category C

Category C: Participant currently has a waiver (approved by SSAI) that has extended their time on SCSEP beyond four years and the participant’s waiver expires on or after Tuesday, October 1, 2013

Example: Participant Gallagher currently has a waiver for Severely Limited Employment Prospects in an area of persistent unemployment that will expire on October 2, 2013. Under the change in policy, Participant Gallagher is not eligible for any more waivers, and project staff must exit him on October 2, 2013.

Category D

Category D: Participant has never had a waiver before and is reaching his/her four-year durational limit for on or after Tuesday, October 1, 2013

Example: Participant Sarmiento was enrolled on January 4, 2010 and will reach his four-year durational limit exit date on January 3, 2014. Under the change in policy, Participant Sarmiento is not eligible for a waiver to the durational limit, and project staff must exit him on January 3, 2014.

What’s the Difference?

Participants in Categories A and B have the possibility of being eligible for a waiver.

Participants in Categories C & D have zero waiver possibilities.

Questions?

Raise Your Hand to Confer by Phone or Send Us a

Note

What Project Staff must do between now and Friday, June

14th SSAI’s current waiver policy is in

effect until COB on Monday, September 30, 2013

However, because DOL will disable SSAI’s Administrator ability in SPARQ during the months of July – September, you must process all waiver information for participants approaching their four year durational limit exit between now and September 30 by Friday, June 14th

Why Friday, June 14, 2013?

Because SSAI staff needs time to review the documentation you submit in order to:

Approve and enter waiver info into SPARQ

Deny initially but work with you to get corrected support documentation in order to approve

Work with you to make sure no participants fall through the cracks

Let’s Start with Categories A & B

SSAI current waiver process is the same except for one added step

Between now and Friday, June 14th, you will call and schedule a meeting with the participants in Categories A and B to determine his/her eligibility for any one of the seven (7) waiver factors

1. Age 75 or older2. Limited English Proficiency (if a language other than English

is the participant’s primary language)3. Low Literacy Skills (if English is the participant’s primary

language)4. Old enough for but not receiving Social Security Title II

benefits5. Severe Disability6. Frail7. Severely limited employment prospects in an area of

persistent unemployment

Meeting can be group or individual

SSAI’s Current Waiver Process

During the meeting, you and the participant complete a SSAI Waiver Update Form and collect the documents that support/verify the participant’s waiver status

Go to SPARQ and check waiver factor and enter date

Fax or mail the completed Waiver Update Form and supporting documentation to SSAI no later than Friday June 14, 2013

Do not email to SSAI staff or send email scsephelp@ssa-i.org as transmitting participant waiver information in these ways can violate the participant’s privacy

To submit to SSAI…

Fax to attention of Kamal: 301-578-8859

Mail to Kamal Elharam via a method that can be tracked (UPS, Fed-X, USPS Delivery Confirmation, etc.):

Kamal ElharamSenior Service America, Inc.8403 Colesville Road, Suite 1200Silver Spring, MD 20910

There is one added step…

Must review and get participant to sign “Change in Policy” Acknowledgement Form

Let’s review sample

Be sure to provide participant with a copy of his/her completed acknowledgement form and keep signed copy in your participant files

DO NOT…

Do not mail the “Change in Policy Acknowledgement” form to participants

Review policy and form with participants in person

Final Steps for Approval

SSAI staff review documents for accuracy and verification of eligibility for waiver

SSAI staff enter durational limit into SPARQ

SSAI sends “approval letter” or “denial letter” to participants

For participants approved after May 22, 2013, SSAI will send them a letter (with a cc to the project director) by the end of June with their new durational limit date

Let’s Take a Minute to Review

Go to the “Waiver Center” on the SSAI Partners’ Page website

1. SSAI Waiver Update Form

2. Waiver Factors and Definitions Handout

3. PowerPoint from “Waiver Factors Webinar” from 2011

4. Reminder: The tables for “persistent unemployment” are updated in April annually. Thus, in each program year, there are two valid tables in existence: one for July 1 – December 31 and one for February 1 – June 30. “Area of persistent unemployment” can be validated if either table verifies the status of the county at any time during the program year. For a participant with a durational limit date on or before June 30th, you can use either table. For a participant with a durational limit date on or after July 1 and before or on September 30, 2013, you must use the July 1 – December 31 table.

Good News!

Most of you have already completed your waiver work with your participants in Category A & B (those with durational limit exit dates between now and September 30th)

If you have not already done so, you still need to meet with the participant to discuss the policy change and get them to sign the “Change in Policy” Acknowledgement Form

What if a Participant in Category A or B does not qualify for a

waiver?We just reviewed the process

and procedures for participants with durational limit exit dates between now and September 30th who will get a waiver or have an existing waiver renewed by Friday, June 14th

What about those participants who don’t qualify for a waiver?

For participants in Categories A or B not eligible for a waiver or who miss

the June 14th deadline:You must:

Meet with participants to explain policy change and complete “Change in Policy Acknowledgement” Form

Send 90 day notification of exit letter (at least 90 days before exit)

Meet with participant and prepare Transition Assessment and IEP (at least 90 days before exit)

Send 30 day exit letter 30 days before exit date (durational limit date) and letter must include grievance procedures

Exit the participant on the date he/she reaches their durational limit

Enter exit date into SPARQ within 5 days of meeting with participant to complete Exit Form

For participants in Categories C and D…

These participants will reach their durational limit exit dates on or after Tuesday, October 1, 2013

You must: Meet with participants to explain policy change and complete

“Change in Policy Acknowledgement” Form

Send 90 day notification of exit letter (at least 90 days before exit)

Meet with participant and prepare Transition Assessment and IEP (at least 90 days before exit but 12 months before exit is what DOL and SSAI require)

Send 30 day exit letter 30 days before exit date (durational limit date) and letter must include grievance procedures

Exit the participant on the date he/she reaches their durational limit

Enter exit date into SPARQ within 5 days of meeting with participant to complete Exit Form

For Participants Not Eligible for a Waiver

Let’s review key documents on the

Partners’ Page90 Day Notice Letter

Transitional Assessment & IEP Form

30 Day Exit Letter

Questions?

Raise Your Hand to Confer by Phone or Send Us a

Note

To help you stay organized…

Weekly Durational Email/Report

Weekly Durational Email/Report

SSAI will send weekly Durational limit email with attached report to Project Directors and coordinators

Report is based on data from SPARQ

D-rejects must be resolved in order to have an accurate date

If you have questions about the date double check the assignment data and approved break data in SPARQ

The email will highlight the Participants reaching their limit in the next 7 days

Participants without an approved waiver request will be expected to exit on their Durational limit date

You have up to 7 days prior and post the durational limit date to enter the exit data. You will not be able to enter exit data for these participants 7 days past their limit – SPARQ will lock the record

The email will help you and SSAI reduce the risk of locked records

Weekly Durational Email/Report

Report includes:

PID (SPARQ Participant ID)

Participant’s last name and first name

Durational limit date – this date is either the 48 month/4 year date or the new date based on the last SSAI approved waiver

Group (A, B, C, or D)

Next steps to take with each participant

Report sorted by durational limit date and show their waiver group

Weekly Durational Email/Report

PID Last Name First Name Durational limit Date Group Next Steps

123456781 Smith John 6/29/2013 Group B Eligible for Waiver. Send paperwork by 6/14/2013

123456782 Smith Mark 8/1/2013 Group A Eligible for Waiver. Send paperwork by 6/14/2013

123456783 Buck Maria 10/5/2013 Group CNot eligible for Waiver. Develop Transitional Assessment IEP

123456784 Castiloo Lesley 2/1/2014 Group CNot eligible for Waiver. Develop Transitional Assessment IEP

123456785 Callier James 7/1/2014 Group CNot eligible for Waiver. Develop Transitional Assessment IEP

… … … 10/1/2014 Group DNot eligible for Waiver. Develop Transitional Assessment IEP

… … … 11/5/2014 Group DNot eligible for Waiver. Develop Transitional Assessment IEP

… … … 2/5/2014 Group DNot eligible for Waiver. Develop Transitional Assessment IEP

… … … 3/6/2014 Group DNot eligible for Waiver. Develop Transitional Assessment IEP

… … … 4/1/2014 Group DNot eligible for Waiver. Develop Transitional Assessment IEP

… … … 6/29/2014 Group DNot eligible for Waiver. Develop Regular Assessments and IEPs

… … … 7/5/2014 Group DNot eligible for Waiver. Develop Regular Assessments and IEPs

… … … 8/1/2014 Group DNot eligible for Waiver. Develop Regular Assessments and IEPs

123456786 Becker Travis 1/1/2015 Group DNot eligible for Waiver. Develop Regular Assessments and IEPs

Questions?

Raise Your Hand to Confer by Phone or Send Us a

Note

Compliance Visit Finding

Many subgrantees are out of compliance with SSAI’s PPM # 301 F and G because project staff are not working with participants who are not waiver eligible to develop a Transition Assessment and IEP

Exiting participants who reach durational limit with no plan for life post SCSEP

Not Acceptable

Transition Assessment and IEP is a required SCSEP service that you are denying the participants

The participants need your full commitment to help them transition as they will no longer ever be able to participate in SCSEP again – anywhere in the country for the rest of their lives

FAQ #1Q: What is the difference between a new participant who has never been on the program below enrolled on May 22, 2013, October 5, 2013 or February 1, 2014?

A: There is no difference. None of these new participants will be eligible for a waiver to the four year/48 month individual durational limit. Until you update your Participant Handbook to reflect the changes in SSAI’s Durational Limit Policy, you must discuss the policy change with all new participants during their orientation and have them sign the “Change in Policy” Acknowledgement Form. Provide the participant with a signed copy and retain a signed copy in your participant files.

SSAI’s Front End Support Team will be preparing an updated Participant Handbook template in PY2013 and will work with all subgrantees to ensure updated Handbooks are in place. There is no need to rush to change your handbook as long as you utilize the “Change in Policy” Acknowledgement Form.

FAQ #2Q: I am concerned about having to enroll a lot of participants in PY2013 as a result of exiting many participants who reach their four year durational limit

A: Please do not worry about this right now. Focus instead on: (1) following the proper waiver policies and procedures and (2) keeping your waiting list vital by prioritizing those waiting and conducting pre-screening to see who is eligible. If you don’t have a wait list but anticipate needing to do a lot of enrollment, then now is a good time to start your SCSEP recruiting and outreach for new host agencies and to build your participant wait list.

In upcoming webinar, we will review PY2013 Project Performance Plan (PPP) process, and we will be helping projects address any enrollment issues as needed.

FAQ #3

Q: What if a participant refuses to sign the “Change in Policy Acknowledgement” Form?

A: Be sure to document on the form the date you met with the participant and a short summary of why he/she refused. Retain a copy of the form and your handwritten notes from the meeting in the participant’s file.

Review Key Waiver Dates

Wednesday, May 22nd – SSAI and subgrantees (who have not already done so) mail notification letters to participants

Thursday, May 23rd – Project staff start calling participants to schedule meetings (use SSAI report to prioritize who to meet with first)

Friday, June 14th – last day for project staff to submit waiver information to SSAI for participants reaching their durational limit dates between now and September 30, 2013 (Categories A or B)

Be sure to discuss policy change and get participant to sign “Change in Policy Acknowledgement” Form

By Friday, June 28th, for any participant in Category A or B (with a durational limit date before or on September 30) who is not waiver eligible, send 90 day notice letter

On-going after June 28th – Project staff use the “Weekly Waiver Email/Report” to stay on top of 90 day letters, Transition Assessments & IEPs, and 30 day notice of exit letters

Questions?

Raise Your Hand to Confer by Phone or Send Us a

Note

What to Expect in Next Three Months from

SSAITaking a different approach

this year based on lessons learned from prior program years

Use the time between now and the end of August, to help you be proactive with regard to your PY2013 performance

Mark Your Calendars June 5 – Network Wide Webinar on Year-End

Data

June 19 – Network Wide Webinar on Continuous Improvement Plans (CIP) for performance

July 10 – last day to enter your Q4 data into SPARQ including hours for April – June

July 17 – Network Wide Webinar on PY2013 Project Performance Plans

July 24 – CIPs and PY2013 Project Performance Plans Due

August 15 - Deadline for SSAI to approve your CIP and PY2013 Project Performance Plans

Any Final Questions?

Raise Your Hand to Confer by Phone or Send Us a

Note

Thank you for attending today’s webinar

If you have questions after the webinar, please contact the Front End Support Team at 301-578-8989 or by email at scsephelp@ssa-i.org

We will send an email with link to today’s webinar recording and copy of the PowerPoint slides