IL

To: Centers for Medicare and Medicaid Services From: Jonathan Lavin, AgeOptions CEO Date: February 15, 2008 Re: CMS-2229-P RIN 0938-AO52 Self-Directed Personal Assistant Services ____________________________________________________________________ ________ Thank you for this opportunity to comment on the Self-Directed Personal Assistant Services. As the Area Agency on Aging for suburban Cook County, Illinois, AgeOptions supports self-direction as part of the full range of choices for care for older adults. AgeOptions commends CMS for its efforts to construct a policy which allows for both autonomy and support, flexibility and risk management, self-direction and plans of care. The safeguards included for budgets, disputes, disenrollment and backup care plans will help ensure that clients who direct their own services receive the care to which they are entitled. In addition, the required state program evaluations will allow CMS to refine the program as needed to enhance quality. We are especially pleased that states will have the option to allow clients to use their budgets for items that ?increase independence or substitute for human assistance?. AgeOptions, through its administration of Illinois? Assistive Technology Demonstration Project in suburban Cook County, has found such purchases to be invaluable to older adults? safety and independence, as well as to their families? peace of mind. AgeOptions has concerns, however, regarding the following elements of CMS- 2229-P: Provisions of the Proposed Rule ? Support System: This section of the rules correctly identifies financial counseling, training and assistance as integral to any successful self-direction program. Specifically, financial training should include check-writing and accounting, as well as payroll and tax preparation for those clients who wish to manage these operations without the assistance of a financial agency. AgeOptions recommends that this counseling be fully funded and integrated with current aging network services (Area Agencies and their partner local service providers). ? Section 441.462 Statewideness, Comparability, and Limitations on Number Served permits states to limit the geographic availability of self-directed services. While AgeOptions understands that comparable services would be available statewide, we recommend that the eventual goal be for all clients regardless of geographical location to have the option to direct their own care.