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12/22/98, 3:13 pmcst

Long-Term care draft plan in Tennessee

By failing to create a plan that will meet even the minimal requirements of the legislative mandate, the planning and advisory councils have doomed Tennessee to continue its downward spiral to a significant crisis in long-term care.


ADAPT and the Centers for Independent Living have written Commissioner Menke with their concerns with the "plan."

December 21, 1998

Dear Commissioner Menke:

ADAPT was pleased being part of the Advisory Council charged with helping develop a comprehensive plan for long term care based on the mandates of Senate Bill 2411. After many months of discussion, we are not surprised that the draft of this plan is in desperate need or revision. ADAPT has taken our commitment to SB 2411 seriously. Therefore, we cannot approve any plan that does not guide future funding, or coordinate and deliver long-term care services.

We feel sure that it is your intention to meet the criteria of SB 2411 when you submit the revised version of the plan to the Council on December 28. We look forward to reviewing a plan that includes consumer control, adequate funding through Medicaid, and real choice for the people of Tennessee.

Free Our People!

Dawn Russell
ADAPT

cc:	Council
	Ariola
	Henry
	Sundquist

Dec. 22, 1998

Dear Commissioner Menke,
Members of the Long Term Care Planning Council and the
Long Term Care Advisory Council,

The Centers for Independent Living and the Statewide Independent Living Council would like to tank each of you for your efforts in developing the Tennessee Comprehensive Plan for the Delivery of Long-Term Care Services to Elderly and Disabled Persons. We are particularly pleased that by providing home and community based services, the plan incorporates certain components of the Independent Living philosophy as promoted by our organizations.

As you will recall, Independent Living as defined by the Rehabilitation Act of 1973, as amended,

"includes a philosophy of consumer control, peer support, self-help, self-determination, equal access, and individual, self, and system advocacy, to maximize the leadership, empowerment, independence, and productivity of individuals with significant disabilities, and the interaction and full inclusion of such individuals into the mainstream of American society."
To that end, the six centers for independent living located throughout the state serve individuals with disabilities with referral and informational services as well as training on independent living skills, peer support and individual and systems advocacy on disability issues. This allows people with disabilities the opportunity for self-determination with regards to all facets of their life including health and social services, housing, transportation and employment. This, in turn, enables those individuals to contribute to the community as well. We all can agree that the opportunity for self-determination by any individual is one none of us as representatives of the citizenry of Tennessee can deny.

We further appreciate the opportunity to review the plan and submit comments for your consideration. The following initial comments are respectfully submitted.

  1. The language in the plan leans towards the needs of the elderly, particularly in Components 2, 4 and 5. Although the majority served will be elderly, everyone served is affected by one or more disabilities.

  2. In addition to the Health Department, we recommend multiple points of entry to facilitate ease of access to the system. These points of entry should be determined based upon their expertise in serving the needs of people who are elderly and disabled, i.e. the Area Agencies on Aging used as entry points for the elderly and the Centers for Independent Living used as entry points for those individuals with disabilities as well as other social service agencies that naturally serve those with long term care needs.

  3. We do not agree with the costs for nursing home and home and community based care as presented in the plan. Nor do we agree with the methodology by which these costs were derived. Information we have received from the Comptroller of the Currency's office indicates an annual cost of $22,940 for Level 1 nursing care. This figure is contradictory to the plan's average per capita cost of $18,387.58. In addition, the HCFA 372 report from North Carolina shows the state saved $6,484 per enrollee on the 1915 (c) waiver. We are curious as to why such a significant difference exists between North Carolina's expenses for home and community based care and those proposed in the plan for Tennessee. A copy of Ron Lee's analysis should be included for examination by legislators and the public. Finally, we request that the plan include the cost of acute care for nursing home care compared to acute care in the community.

  4. It is critical that the plan reflect an aggregate cap for costs. We commend you for the inclusion of a broad array of services. This coupled with an aggregate cap will ensure equity among all served by the plan including those with the most significant disabilities. We oppose a reduction in the services offered in order to reduce or contain costs.
We thank you for your recognition of our comments with regard to the plan. We look forward to their inclusion in the plan as they reflect a more effective and efficient way to serve the needs of people who are elderly and disabled in their homes and communities. We applaud your efforts in doing the right thing.

Sincerely,

Janet Kidd, Executive Director
Center for Independent Living of Middle Tennessee, Nashville, TN

Susan Stacy, Executive Director
Disability Resource Center, Knoxville, TN

Deborah Cunningham, Executive Director
Memphis Center for Independent Living

Glenn Barr, Executive Director
Jackson Center for Independent Living

Michael Bliss, Executive Director
Tri-State Resources and Advocacy Corporation, Chattanooga, TN

Marti Finch, Executive Director
Northeast Tennessee Center for Independent Living, Bristol, TN

Kimberly M. Hines, Executive Director
The Statewide Independent Living Council


cc:	Representative John Ariola
	Senator Doug Henry
	Governor Don Sundquist


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