Compilation of Membership’s Best Practices
Principles & Guidelines: Program Design / Structure
- CDPAP (Consumer Directed Personal Assistance Program) programs allow Consumers to independently recruit, hire, train, supervise and (if need be) terminate the Personal Assistants (PAs) they choose to work with. Regardless of the level of assistance, the Fiscal Intermediary (FI), the organization who administers the program, maintains a clear line of separation between their role and the role of the consumer. This separation affords the CDPAP a reasonable liability position and prevents any interference with the consumer’s goal of empowerment;
- Even though FIs are motivated by a variety of considerations from advocacy to control, they avoid the direct training or orientation of the PA, or the development of any program that requires consumers to select from a list of approved or prescreened PAs. For consumers to be truly empowered, FIs must respect each of the responsibilities that the Consumer has accepted. FIs insure that any procedures they adopt do not overshadow or negate any of the consumer’s prerogatives;
- FIs provide clear guidelines for consumers and PAs to understand and be responsible for;
- FIs offer as much assistance as their program design and budget will permit. This assistance can include, consumer counseling and orientation, including, but not limited to, universal precautions, providing a safe work environment, proper equipment, steps involved in training PAs, offering training media such as video / DVD / books / seminars, etc. Also, recruitment assistance, the flexibility to pay trainees and the provision of a competitive wage and employee benefit to enhance the consumer’s ability to recruit and retain PAs;
- FIs provide discrete program monitoring within the context of the consumer’s responsibilities so that if any issues arise the FI can work with the consumer and the county caseworker to rectify the issues;
- FIs establish ongoing communication with consumers, which may include random phone conversations.
- FIs “post” definitions and consequences, for example, having a signed statement on time sheets that consumers and PAs attest to;
- FIs verify Personal Assistant’s Social Security Numbers to ensure that only valid individuals are put into payroll;
- FIs maintain open communication with Department of Social Services’ Caseworkers so that everyone is aware of the strengths and weaknesses in a consumer’s management style. If that person needs additional training, it is recognized quickly;
- Although FIs may have to impose employment standards and limitations on the PA enrollment process, they refrain from complicating the enrollment process by imposing any standards that are not specifically imposed upon it by the program’s design or by outside regulators;
- FIs design systems that are both user friendly and consumer empowering, to address the requirements imposed upon them by their program’s design and by Federal, State and Local Regulators. Systems are designed realizing that consumers will approach the program’s requirements from vastly different levels of experience and education. Systems are also designed with a level of flexibility that permits consumers to rapidly hire emergency PAs when needed; and
- To permit the program to empower consumers, FIs avoid using any system that bypasses the consumer, even if the system is technologically superior or administratively easier. FIs keep the consumer actively involved in the enrollment, time sheet data collection and payroll distribution processes. This involvement significantly enhances the consumer’s sense of authority over the PA management process, even if the program’s design makes this involvement technically symbolic.
Principles & Guidelines: Program Operation
- Fiscal Intermediaries (FIs) perform random signature verifications on time sheets / paychecks;
- FIs develop time sheet processing procedures that recognize potential issues. If there are any discrepancies, FI program staff should follow up quickly and directly. This sends the message that staff are available and monitoring program usage;
- FIs request original time sheets back from Consumers if they are faxed;
- FIs document (take notes) and track trends and events because they may be helpful if a controversy arises;
- FIs send certified letters to the county documenting issues so that program integrity is protected;
- FIs establish an investigation system whereby every anonymous tip alleging consumers / personal assistants (PAs) of fraudulent behavior is investigated. It is helpful for all parties to know this from the onset of using the program so there are no bad feelings;
- FIs develop Frequently Asked Questions (FAQ) and /or “Do’s & Don’ts” lists to heighten consumer’s awareness of crucial program aspects;
- FIs enlist methods of peer support to ensure “first-hand” comprehension of programmatic concepts and responsibilities;
- FIs provide fax machines directly to consumers to ensure paperwork is submitted by the consumer him or herself
Underlying Consumer Directed Personal Assistance Program’ Model Facts:
- Consumers cannot “self-refer” themselves to the program – they are assessed and approved by a county caseworker and a nurse to gain entry to the program and every six months thereafter;
- Since it is the county caseworker and nurse who determines the number of paid weekly hours based on each consumer’s specific needs, and the Fiscal Intermediary (FI) oversees and processes time sheets containing that weekly amount of hours, oversight is built in. It is the county who controls the number of hours that consumers may access;
- The Personal Assistant’s (PA) health is assessed on a yearly basis exactly as it is under traditional personal care programs.
- Consumers and PAs certify that all tasks are completed in accordance with the consumer’s plan of care within both models of traditional personal care and CDPAP.
- In order to participate in the program, consumers must have a back-up system in place in the event that a PA cannot arrive at his or her shift. In this way, no consumer is ever left without care.
- Clinical evidence has shown that self-directing individuals are not only capable, but better at, defining how best to live their lives. This means that in most cases, the highest standards met.
- CDPAP is a model that began in New York, but has been replicated nationwide. In California, over half of home care is delivered through Consumer Directed Personal Assistance.
- The primary objective of a CDPAP FI is to develop and perform ongoing systematic monitoring of all aspects of the fiscal and service cycle. Home care affords community choice; it is not a breeding ground for fraud.
- Personal Assistants are trained to provide the services they deliver. Consumers legally train them to perform the tasks they need done – whether those tasks are medical or not. The United States Veteran’s Administration has trained and paid family members of disabled veterans long before the consumer driven focus was ever considered.