CIH Waiver Amendment Public Comment from The Arc of Indiana

The following comments were submitted by The Arc of Indiana to Indiana’s Division of Disability and Rehabilitative Services regarding the proposed amendment to the Community Integration and Habilitation (CIH) Waiver.


The Arc of Indiana is a state-wide organization that advocates on behalf of people with intellectual and other developmental disabilities and their families.  We have 43 local chapters providing a variety of services from family advocacy to delivering the most personal and critical care.

We appreciate the opportunity to provide comments regarding the proposed amendment to the Community Integration and Habilitation (CIH) Waiver regarding provider rates.

Across the state our chapters are facing a shortage of qualified direct support professionals (DSPs).  A shortage of DSPs jeopardizes the quality of care for thousands of people with disabilities throughout our state.  A barrier to hiring and attracting qualified, dedicated workers is the rates for reimbursement under the waiver. Providers are under strict financial constraints and reimbursement rates that have not kept up with the rate of inflation and increasing costs of business add to an already difficult situation.  We appreciate that the state is getting ready to increase the reimbursement rates for these critical services and hope it will lead to better workers and services for people with intellectual and other developmental disabilities.  Families throughout our state depend on these services to keep their loved ones at home or in nearby communities.

The state over the last decade has cut reimbursement rates in an effort to maintain a balanced budget and create a large rainy day fund.   These cuts have led local service providers to seriously look at what services they can continue to offer and what they can afford to pay their workers. Many direct support professionals work at more than one job to make ends meet and many qualify for government assistance themselves because they do not earn a meaningful income.

During the 2015 legislative session, The Arc of Indiana strongly supported and actively worked to see a budget bill passed by the Indiana General Assembly that increased the reimbursement rates of waiver services and succeeded in restoring rates back to 2010 levels. A rate which is still grossly under the cost of providing services.

Throughout the legislative process we discussed with legislators the need to increase reimbursement rates while not having a negative impact on those receiving the services.  It certainly was not the intent of the legislature that people with disabilities utilizing the waiver would have a decrease of services due to the reimbursement rates being increased.

In 2015, The Arc of Indiana completed its updated, “Blueprint for Change, Next Steps in the Journey.”  Building a workforce for people with intellectual and other developmental disabilities was one of the five priorities outlined in the plan.  Direct Support Professionals (DSPs) who work with people with disabilities often act as the glue that helps hold a family or small group of adults together.

Roughly 50,000 full-and part-time DSPs work for Indiana agencies to assist individuals through the Medicaid waiver system.  However, these vital workers are typically paid a wage that leaves them struggling – which in turn adds more burden to Indiana’s support system. Indiana DSPs make an average of $10.20 per hour according to a study completed in 2014.  This compensation puts them substantially behind many other occupations, and even below the poverty level.  More than half say they are the primary wage earner in their household, and nearly 30 percent must work a second job.

Many experts in the field believe we will not reach a stable workforce until DSPs make at least $15.00 hourly, which would allow them to develop their jobs into a long-term career.  Since labor represents nearly 80 percent of Medicaid Waiver costs, that is a challenging number to achieve.

As Indiana looks to increase its reimbursement rates for certain waiver services, we strongly encourage doing so without decreasing the services available to waiver recipients.  The Indiana legislature took a step toward addressing the compensation gap of DSPs in Indiana with the intent that services and support for people with disabilities would become more stable.

In addition, every year we see millions of dollars reverted from the Family and Social Services Administration (FSSA) back to the state’s general fund account.  Monies appropriated from the Indiana General Assembly for critical programs are not being utilized for their intended purpose.  This further shows that there are available resources to increase reimbursement rates without cutting services to Indiana’s most vulnerable citizens.

The Arc of Indiana certainly understands the pressure of making budgets work.  However, decreasing services to people with intellectual and other developmental disabilities to make room for an increase in reimbursement rates for certain waiver services goes against the intent of the language in HEA 1001-2015 regarding reimbursement rates.

Again, we appreciate the opportunity to provide comments and offer our assistance in any way appropriate.

Respectfully Submitted,

Kim Dodson
Executive Director