Office of Developmental Programs

625 Forster Street

Room 510

Harrisburg, Pa 17120

October 7, 2019

RE:  Comments on the Adult Autism Waiver Amendments

MAX members thank the Office of Developmental Programs for the opportunity to comment on the Adult Autism Waiver Amendments (AAW).

GENERAL COMMENTS

• MAX questions the need for a separate Autism Waiver and suggests ODP look at the benefits to service recipients as well as efficiencies to ODP, of eliminating this waiver especially since individuals with autism can enroll in the PFDS, Consolidated and Community Living Waivers.  MAX would support this only with the assurance of no service reduction to individuals currently receiving services as well as the number of service recipients.

With this said, MAX offers the comments below in the event the AAW remains a separate waiver.

Consistency with other ODP waivers

In general, the amendments begin a movement in the right direction of better aligning the AAW with the other ODP waivers.  But work still needs to be done, especially, AAW and other ODP waivers should not have different rates for the same services. 

Addition of Self Determination Services

            In accordance with the current movement towards self-direction, MAX suggests adding this option to the AAW.

Fee Structure

In general, MAX advocates that the fee structure is established with transparency and input from stakeholders.  All rate formularies and assumptions used to determine rates and allowable costs must be fully disclosed for commentators to give informed feedback.

Rates

Proposed fees for Systemic skill building ($15.37) and community supports ($9.00)  are too low given the expected experience and other credentials staff  will need to possess in order to provide these services.  Given the workforce crisis, this will only add to staff vacancies and wait times to receive these services. 

Transportation Cap

The proposed cap for transportation services is too low.  This will only fund 126 days at Zone 1 and 62 days at Zone 3.  Since transportation is a critical service underpinning community participation opportunities, MAX urges the cap be raised.

Staff training

Proposed training for supported employment staff requires an additional 8 hours of training from the Bureau of Autism Services.  This additional training has yielded failing results for highly trained, educated and seasoned staff.  MAX suggests ODP evaluate this test and redesign it to more effectively accomplish positive results.

Again, thank you for the opportunity to offer comments on the proposed Adult Autism Waiver amendments.

Sincerely,

Diane Conway, Ph.D.

Executive Director

MAX Association