LRS and People First of Ohio jointly submit comments on proposed SELF waiver rules

The Ohio Legal Rights Service (LRS) and People First of Ohio (PFO) provided comments to the Ohio Department of Developmental Disabilities (DODD) on proposed rules to implement the Self-Empowered Life Funding (SELF) waiver. Although LRS and PFO support the participant-directed principles of the waiver, both are concerned about the proposed individual caps of $25,000 for children and $40,000 for adults. LRS and PFO stated it appears these caps are designed for administrative ease and alleviating county budget challenges rather than addressing the needs of individuals or promoting system-wide rebalancing.

Another concern is that the proposed rules do not include any provision for prior authorization. This is particularly important if additional or emergency resources are necessary to protect the health and safety of an individual. In addition, LRS and PFO commented that the rules fail to address the critically important issue of matching-fund elevation, similar to changes implemented in Ohio's behavioral health systems.

LRS and PFO recommended the expansion of the Individual Options (IO) waiver, which presently has a waiting list of nearly 27,000 people, as the ideal method to rebalance Ohio's developmental disabilities system. The IO waiver does not have an individual cap and evidence indicates that the IO waiver is a cost-effective use of resources in comparison to expensive institutional settings. While the needs of some individuals could be fulfilled within the limits of the SELF waiver, there are countless others with more extensive needs who are not enrolled on the IO waiver and who would therefore remain institutionalized or at risk of institutionalization because of these caps.

Read the comments: Public Hearing Comments on SELF Waiver Proposed Rules (PDF file)

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