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DDES Memo Series 2004-03

February 5, 2004

STATE OF WISCONSIN
Department of Health and Family Services
Division of Disability and Elder Services

To:
Area Administrators/Assistant Area Administrators-Adult Services
DDES Bureau/Office Directors
COP Lead Agency Directors
County Aging Units Directors
County COP Coordinators
County COP-Waiver Coordinators
County Departments of Community Programs Directors
County Departments of Developmental Disabilities Services Directors
County Departments of Human Service Directors
County Departments of Social Service Directors
County LTS Planning Committee Chairpersons Section Chiefs
Tribal Chairpersons/Human Services Facilitators

FROM: 
Sinikka Santala
Administrator

Re: Limiting COP Used as Match

This memo establishes a requirement for the Community Options Program (COP) managers to comply with the statutory purposes of the program to serve a significant proportion of all target groups, including persons not eligible for a waiver, and to pay for goods and services not permitted within federal waivers (known as "gap-filling.") 

Community Options funds are increasingly used for match for the Community Integration Program to such an extent that people with physical disabilities, elderly people and people with serious mental illness in many counties do not have equitable access to the limited COP program funds. 

Beginning January 2004, County COP lead agencies are required to limit the amount of COP used as CIP I match or overmatch to 2002 levels or to 25% of its COP regular service allocation, whichever is greater.

Background
The Community Options Program provides flexible funding for persons who are low income and eligible for care in a nursing home. The statutes require that COP funding be used for a significant number of persons in each of five target groups. Department policy set the following percentages in 1995: elders-57%, individuals with developmental disabilities-14%, individuals with physical disabilities-6.6%, individuals with serious mental illness 6.6%, AODA-no minimum.

Although the target percentage for elderly people has not been increased to reflect the demographic growth of this population, the required proportion for elders has not been met statewide since 1999. Many counties do not meet the minimum requirement for serving persons with serious mental illness.

Over the years, with expansion of the federal home and community based waivers programs, the way COP funding has been used has changed. While originally it funded service alternatives to nursing homes, it later became a gap-filler when federal waiver funding was not appropriate. 

Recently it has been used as local match for capturing additional waiver funds. In 2002, 38% COP funding was used as match for waiver eligible persons, as 13% as overmatch for costs above the allocated slot value, 25% for persons not eligible for a waiver and 15% for non-waiver allowable services.

Almost all funding used for match and overmatch is used for persons with a developmental disability (in 2002, 87% was used as match and 90% used as overmatch for those with developmental disabilities). Over the past three years the amounts used in this way have increased each year. 

The COP funds used as overmatch are not generally one time expenditures but become a permanent part of the base funding for the CIP program, and not available in subsequent years for other target groups. As older persons and persons with physical disabilities leave the program, more funds are directed to serving people with developmental disabilities. 

COP funding for people who are elderly, physically disabled or mentally ill has remained constant or declined every year for the past five years. Legislative intent throughout the history of COP has been expressed in requirements to serve all target groups equitably.

Policy for CY 2004
In order to ensure a more equitable access to COP funds in the future, counties shall limit the amount of their COP allocation that is used as match or overmatch for CIP I to the levels used for this purpose in 2002.

• Counties may increase the amount of COP funding used for CIP I match up to 25%, if their CY 2002 levels were below 25% of their COP expenditures.
  
• Counties that have exceeded this level in 2003, will have to request a variance to go up to, but not exceed, their 2003 level.
  
• The Department will monitor the outcome of this policy to determine whether the numbers of under-served target group members remains constant or increases.
  
• The Department does not propose to reduce COP funding for any target group. Nevertheless, to ensure that COP continues to be available to all groups for its intended purposes, limits will be placed so that no additional COP is used as match for CIP I in counties that already use in excess of 25% of COP for match or overmatch.

In June 2003, counties were alerted to the Department’s intent to implement this strategy when it was announced in DDES Informational Memo 2003-01 regarding time-limited federal match. Counties were notified at that time so they could plan for calendar year 2004 to equitably fund services for all target groups during the current fiscal crisis.

Attached is a chart which shows by county the percentage of COP service funds used for CIP I match or overmatch in 2002.

REGIONAL CONTACT:
Assistant Area Administrator-Adult Services

CENTRAL OFFICE CONTACTS:

MEMO WEB SITE: 
http://www.dhs.wisconsin.gov/partners/local.htm

c: 
Area Agencies on Aging
Wisconsin Council of Developmental Disabilities
Wisconsin Coalition for Advocacy
Mental Health Council
Physical Disabilities Council

ATTACHMENT:

Date:  10/8/03
Maximum Amount of COP Funding Available in CY 04 for CIP I local match/overmatch

*County Agency is exempt from this cap
**Family Care Counties - exempt from this cap
Source: COP CY 02 reconciliation schedules

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