Pat Quinn, Governor
The answers to the following questions are intended to provide assistance to adult day service and/or in-home care providers interested in applying for certification under the Community Care Program (CCP). The Department administers separate schedules to certify and procure providers for case management and emergency home response services under this program. The answers do not constitute binding legal opinions. Additional clarification may be provided in the future regarding specific questions depending upon policy changes.
What is the Community Care Program?
The Community Care Program (CCP) is a public benefit entitlement program offering in-home and community-based services for qualified senior citizens (age 60+) as an alternative to inappropriate or premature nursing home placement. It is administered by the Illinois Department on Aging (the Department) as a privatized service delivery system.
What services are offered under CCP?
The CCP clients are offered any combination of the following non-medical services: case management, emergency home response, in-home care or adult day services, as appropriate, to meet individual needs.
How does CCP work?
Services are provided to clients at the local level through a statewide network of independent agencies who have first been certified as qualified, then completed required management training, and thereafter executed provider agreements with the Department under CCP.
Clients have freedom of choice in selecting a service provider agency from among those serving the client’s geographic area. If a client prefers not to choose a provider, the client will be referred to a provider through a rotation system which gives every provider in the service area equal access to clients. Once selected, the provider then serves the client according to an individualized plan of care.
Provider agency employees who serve the clients are the Department’s primary link to each client under CCP. They provide alerts as to physical changes in a client or to changes in a client’s environment, which may require a reassessment of service needs.
What is the role of the Department?
The Department administers CCP by setting service standards, reviewing provider qualifications for possible certification, entering into contractual agreements for the purchase of care with certified provider agencies, monitoring service delivery and conducting provider performance reviews for quality improvement purposes, and approving or reconciling provider billings for payment.
How does an entity become a CCP provider?
An entity may become a provider by seeking certification under CCP. If an applicant agency meets various program requirements set by the Department, it will be certified as a qualified CCP provider for a specific service and scheduled for CCP Management Training. Upon successful completion of CCP Management Training, the Department will afford the applicant agency an opportunity to execute a Provider Agreement.
Are there rules for CCP?
Yes. The CCP rules may be accessed at the Illinois General Assembly Web site.
These rules contain complete information on CCP and must be adhered to by every certified provider agency awarded a CCP Provider Agreement. Each applicant is strongly advised to become familiar with these rules before completing a certification packet.
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What is Case Management?
Case management involves both the initial eligibility determination process for CCP and development of individualized plans of care, which are subject to reassessment on an annual basis absent intervening changes. This type of service is provided by Case Coordination Units.
What is In-Home Service?
In-home service is defined as general non-medical support by supervised homecare aides who have received specialized training in the provision of this service. The purpose of providing in-home service is to maintain, strengthen and safeguard the functioning of individuals in their own homes in accordance with the authorized plan of care.
What services are included in CCP In-Home Service?
Some of the required in-home services include:
For a detailed list of in-home services, refer to the CCP rules, Section 240.210.
What is Adult Day Service?
Adult Day Service is defined as the direct care and supervision of adults age 60 and over in a community-based setting for the purpose of providing personal attention and promoting social, physical and emotional well-being in a structured setting.
What services are included in CCP Adult Day Service?
Some of the required adult day services include:
For a detailed list of adult day services, refer to the CCP rules, Section 240.230.
What are the requirements for an Adult Day Service facility?
Adult day service facilities must include a minimum of 40 square feet of activity area per client and must meet all local and state codes and requirements, such as plumbing, building and fire safety. Facilities also must be accessible to persons with disabilities.
For more information about adult day service facility requirements, refer to the CCP rules, Section 240.1550.
Is there a list of current CCP provider agencies and their respective service areas?
Yes. The Department maintains a list of current CCP providers. See Directory of Agencies Serving Seniors and scroll down to select the appropriate type of service provider agency.
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How are CCP clients referred to my agency?
After a Case Coordination Unit (CCU) determines that an individual is eligible for CCP and develops a plan of care for the new client, the client may select a provider from among those serving the client’s geographic area. If a client does not choose a provider, the Department has established a rotation plan for referrals. The proportionate share of new referrals will vary by the number of providers in the same geographic service area.
Official notification is made by the CCU with information about the client, the services to be provided, and the initial service date. The agency will be required to provide services within 15 days* from the date the agency is notified.
All clients referred by choice or rotation to respective providers must be accepted and served within the required time frames. The provider must have sufficient back-up personnel to ensure service if there is an unexpected increase in client caseload.
*NOTE: The agency will be required to provide service within two work days from the date the agency is notified if a client is at imminent risk of nursing home placement.
How many CCP clients can a provider agency expect to serve?
The Department cannot establish contractually either the number of clients referred to a provider or the number of units of service provided by a provider. Therefore, the successful provider applicant must be prepared at any time to receive new clients and to serve those clients within required time frames. Only the rate of reimbursement per unit of service delivered can be established contractually by the Department.
Is a provider agency allowed to operate from a private residence?
No. The CCP rules require provider agencies to operate a place of business in a properly zoned area.
Is a provider agency allowed to use volunteers?
Yes. The CCP rules do not prohibit provider agencies from using volunteers; however, any volunteers used to serve CCP clients must meet the same requirements as paid staff, including criminal background checks and annual training requirements.
NOTE: In-home service providers who use volunteers to serve CCP clients are still required to expend a minimum of 77% of the total revenues due from the Department for direct service worker costs. For more information about provider financial reporting requirements, refer to the CCP rules, Sections 240.2020 - 240.2050.
What are the insurance requirements for CCP provider agencies?
CCP provider agencies are required to carry general liability insurance; workers compensation for direct service staff; volunteer protection, if volunteers are used; and motor vehicle liability, uninsured motorist and medical payment coverage, if agency staff transports clients in agency vehicles. For more information about minimum insurance requirements, refer to the CCP rules, Section 240.1520.
NOTE: The insurance requirements represent the minimum coverage for liability purposes in operating a business. An agency should consult a professional advisor about the possibility of additional insurance needs as part of its risk management practices.
If there are any changes in the CCP rules, when must a CCP provider comply with the new requirements?
A current CCP provider must comply with new requirements in the CCP rules as directed by the Department. For example, various amendments to the CCP rules were recently adopted by the Department with an effective date of March 23, 2009. Shortly thereafter, upon publication of a notice in the Illinois Register early in April, the Department sent out a separate notification via email to all current CCP providers to announce promulgation of the new rules in order to proceed with implementation of programmatic changes under the CCP. The notification informed provider agencies that the Department would begin to monitor for compliance starting 30 days after issuance of the notice.
What should a provider agency do if it cannot comply with new rules upon notification by the Department?
A provider agency should always act in a proactive manner and contact the Department if it is encountering any unusual circumstances that impede full compliance with rule changes in a timely manner.
NOTE: Any agency that intends to cease being a service provider under CCP must give at least 30 days’ written notice to the Department to minimize disruption to clients in transferring the caseload to another vendor.
Can a current CCP provider unilaterally change the services that it proposed to offer in its Request for Proposal under a prior procurement now that new agreements are being issued by the Department based on different standards under new CCP rules?
No. A CCP provider cannot make unilateral changes in its old service contract with the Department under the CCP. It must continue to offer services as described in any prior Request for Proposal that was used by the Department in awarding a contract under the CCP until expiration of the agreed upon term or the provider is successfully certified for the first time under the new CCP rules and the agency enters into a new agreement with the Department.
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Are start-up funds available for new provider agencies under the CCP?
How does a provider agency bill the Department for CCP service?
After services are provided to a CCP client, the provider agency submits its bill (called a Vendor Request for Payment) to the Department electronically through an Internet-based system, the Electronic Community Care Program Information System (eCCPIS). All CPP providers therefore need to have access to a computer and internet services. For more information about billing requirements, refer to the CCP rules, Section 240.1520.
How is the reimbursement to a CCP provider agency calculated?
Agencies are reimbursed at a fixed unit rate set for a service under a Provider Agreement. Payment is based on the number of units of service provided (and accepted for invoicing) per client for a monthly service period. Payment is subject to the availability of appropriations during the State fiscal year.
What are the reimbursement rates for providing CCP services?
The Department has established the following fixed unit rates of reimbursement per unit of service delivered to each CCP client:
Can a client be billed for the difference if the provider agency normally charges more for a service than the reimbursement rate offered by the Department under CCP?
No. The fixed unit rate of reimbursement set for a service is the full payment for all rule required services provided to CCP clients by an agency under the Provider Agreement. However, a CCP client and a provider agency may enter into a separate agreement at a different rate for additional service hours or types of services that are not included in the authorized care plan developed by the Case Coordination Unit.
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What is the procurement process for CCP?
The CCP is an open procurement process. Any willing and qualified agency may participate by seeking certification as a service provider from the Department at any time. For more information about the certification process, refer to the CCP rules, Section 240.1600.
How does an entity apply for certification?
An entity must complete and submit a certification packet (i.e., both a Legal Entity Application and the appropriate Service Specific Application(s)) to the Department. For applications, instructions and other information about the certification process, see CCP Procurement Opportunities.
What must be included in the certification packet?
A complete certification packet includes the Legal Entity Application and at least one appropriate Service Specific Application, plus all required Attachments. One copy of each application must contain the original dated and notarized signature of an Authorized Representative of the applicant. Applicants are strongly urged to examine and review the certification packet before submission to ensure that it contains all required information. Information should also be submitted in the necessary order with appropriate labels for identification purposes in case the contents would become separated during processing.
NOTE: An "authorized representative" is defined as an owner, officer or employee of the applicant agency or other designated person who has the authority to commit the agency to a financial and/or contractual responsibility.
Is there a difference in the geographic service area for different types of CCP service providers?
Yes. For in-home service, appropriate Service Specific Applications must be submitted by Planning and Service Area. For adult day service, appropriate Service Specific Applications must be submitted by site. However, a Legal Entity Application must be submitted with the application(s) for either service.
NOTE: Only one Legal Entity Application is required regardless of the number and/or type of Service Specific Application submitted to the Department.
What happens if an incomplete or otherwise inadequate certification packet is submitted?
An incomplete or inadequate certification packet (e.g., one submitted in a form and manner other than that prescribed by the Department) will be rejected. Please do not sacrifice completeness for timeliness and be sure that a packet is complete before it is submitted.
NOTE: A provider agency has 30 calendar days to submit any additional information requested by the Department. If information is not submitted in a timely manner, then the Department will close out its file on the request for certification of qualifications. Another packet cannot be submitted for 60 days.
What steps are involved in the CCP Service Provider Certification Process?
There are six steps:
Has a schedule been established for processing certification packets?
Yes. For administrative phase-in purposes, the Department is beginning with Planning and Service Areas (PSAs) 08, 09, 10 and 11; then PSAs 04, 05, 06 and 07; after that, PSAs 01, 02, and 03; and, finally, PSAs 12 and 13 will be processed, as shown on the PSA Map. The schedule will depend upon the time it takes to process packets for the preceding opened area and operating needs under the CCP. This means that there could be a delay between Department receipt of an agency’s packet and the review and processing of it. The Department will post a tentative review schedule, which is subject to change. Please consult CCP Procurement Opportunities before contacting the Department regarding the status of any particular certification packet.
Is there a deadline for current CCP service providers to submit certification packets?
No. A certification packet may be submitted at any time. However, if a current CCP service provider intends to continue under this program, then it should submit a certification packet as soon as possible once a PSA has been opened. The Department has set aside time for review and processing of packets in each PSA and provider delay could result in a slower processing schedule. Also, if a current CCP service provider does not respond within 4 months after a PSA has been opened during the initial phase-in of this certification process, the Department will begin to transfer CCP clients served by the non-responding provider to other newly certified providers in the area.
What happens if a certification packet is submitted before a Planning and Service Area (PSA) has been opened?
The certification packet will be held by the Department until the PSA is opened.
What elements does the Department review in determining provider qualifications?
The following elements will be reviewed to determine provider qualifications:
Can additional information be submitted once a certification packet has been submitted to the Department?
Possibly, but only under limited circumstances. The Department will review the material submitted in a certification packet and, if necessary, may request additional information. If additional information is requested by the Department, the applicant agency has 30 calendar days from the date of request to submit this information. After 60 calendar days, the applicant agency's request for certification of qualifications will be closed and all information must be resubmitted to the Department.
How long does the certification process take?
The length of the certification process varies depending upon a number of factors. On average, during the initial certification process which the Department will implement through Fiscal Year 2010, it may take approximately 3 - 4 months from the point of application to the time of signing a contractual agreement. Thereafter, agreements will be awarded on a schedule determined by the Department, but no more frequently than semi-annually.
Is a certification packet subject to the Freedom of Information Act (FOIA)?
Yes. A certification packet submitted to the Department may be subject to the FOIA. If an applicant agency’s packet contains proprietary information which should not be disclosed, please label each page of this information as "Proprietary." Common examples of proprietary information include a business plan, audited financial report, and other types of information that would not ordinarily be publicly disclosed. The Office of the General Counsel of the Department will make the final determination whether the information qualifies as proprietary but, if no pages are labeled, the application in its entirety is subject to release under FOIA.
What should an entity expect at the pre-certification on-site review?
A pre-certification on-site review will be completed by the Department or its designee. It will be conducted at a mutually agreeable date and time set by the reviewer and the applicant agency. At this time, the review team may ask questions regarding the agency’s organizational structure, the physical site, the population of clients served, and other service-related questions to determine compliance ability with CCP policies. Agencies are expected to have staff available to answer questions about the site. These reviews will take a nominal amount of time.
Is a pre-certification on-site review necessary if a provider agency has completed a full performance review within 12 months prior to application?
Probably not. Every provider agency certified by the Department must have a pre-certification on-site review. For current CCP providers, this requirement is met if a full performance review has been successfully completed within 12 months prior to the date of application. However, a pre-certification on-site review may be necessary if a provider that is subject to a pending contract action is not making satisfactory progress to resolve findings during the applicable timeframe for correction action.
NOTE: The Department reserves the right to conduct a performance review of a contracted provider agency at any time during the course of the provider's contract period.
Where should a completed certification packet be submitted?
Illinois Department on Aging
It is the applicant’s responsibility to ensure that the certification packet is complete.
Is there any technical assistance available for ethnic or language minority applicants?
For assistance regarding language interpretation, contact the Department on Aging Senior HelpLine. Applicants who serve an ethnic or language minority population will be referred to the Coalition of Limited-English Speaking Elderly (CLESE). CLESE staff will return the call to answer any questions about the CCP and/or the certification process. CLESE can help the applicant understand the application instructions and program requirements and may assist in completing the certification packet.
Who can be contacted with questions?
For questions about the application process or completion of the certification packet, contact:
For questions about the Community Care Program rules, policies and procedures, contact:
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What is CCP Management Training?
CCP Management Training is a course sponsored by the Department for agencies that have received a Service Provider Certification. It must be completed before a Provider Agreement can be executed with the Department.
NOTE: Agencies may also attend optional training offered by the CCP provider associations or other entities. This training is not required for certification but will be helpful to those applicants new to the CCP.
Will agencies be allowed to attend Management Training before being certified?
No. An agency must complete the application phase and the on-site review, in order, before attending Management Training as the next step in the certification process.
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What is a CCP Service Provider Agreement?
The CCP Service Provider Agreement is a written contract between the Department and a certified agency for the purchase of care. It sets out all of the terms and conditions for the delivery of service(s) to eligible individuals.
Is an agency an independent contractor under the CCP Service Provider Agreement?
Yes. Service provider agencies are independent contractors of the Department under CCP.
Acceptance and signing of a CCP Service Provider Agreement, as offered by the Department, serves as an assurance that the provider agency will commence delivery of service(s) upon the effective date of the Agreement and will meet all other requirements of the Agreement, including compliance with all CCP rules.
The sole contractual liability of the Department is to make payment for appropriate delivery of service(s) to eligible individuals. These payments are contingent upon such funds as are made available by the General Assembly of the State of Illinois or the Federal Government for the conduct of this program.
Can an agency assign a CCP Service Provider Agreement?
No. Assignment of a CCP Service Provider Agreement is prohibited.
What is the term of a CCP Service Provider Agreement?
Provider Agreements offered to successful applicants will be for a term not to exceed three (3) years.
Does issuance of a Purchase of Service Agreement guarantee that the provider agency will be the only one in a particular geographic service area?
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Is there a Recertification Process?
Yes. The Department, or its designee, shall conduct recertification of each certified provider agency with a valid CCP Service Provider Agreement no less frequently than every 3 years to determine continued compliance with qualifications for the applicable service. Qualified provider agencies will be recertified and afforded the opportunity to execute renewal of the Provider Agreement for the applicable service.
What is the term of a CCP Service Provider Agreement at recertification?
Provider Agreements offered to successful applicants at recertification will be for a term not to exceed three (3) years.
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Does the Department want to see a business plan and audited financial report for the entire applicant agency or just service specific information?
The business plan and audited financial report should show how the specific service for which certification is being sought relates to information about the entire applicant agency. This information should coincide with the strategic plan of the applicant agency. Although the relevant topics to be included are determined by the business for itself, typical information would include a formal listing of business goals for the future, the reasons why the goals are necessary and attainable, and the plans for reaching the goals. This information will be used by the Department to help understand the overall business prospects of the applicant agency.
Is any help available with developing a business plan and strategic plan?
Yes. There are templates available from a variety of sources to help develop a cover sheet; table of contents; executive summary; description of the business, its market and competition; available products, technology, and/or services, including current usage, growth, marketing, and risks; financial data; and management expertise in terms of strengths, weaknesses, and/or opportunities; and other information unique to the business.
Who should prepare the audited financial report?
The audited financial report should be prepared by an independent Certified Public Accountant.
Section 240.1520(n) of the CCP rules states: "Providers shall provide the Department with an annual audit report to be completed by an independent Certified Public Accountant and in accordance with 74 Illinois Administrative Code 420, Subpart D. The audit report shall be filed at the office of the Illinois Department on Aging, 421 East Capitol Avenue, #100, Springfield, Illinois 62701-1789, within 6 months from the date of the close of the provider's business fiscal year."
Why does the Department require assets sufficient to cover 90 days of CCP operating expenses?
The Department requires assets sufficient to cover 90 days of CCP operating expenses as a reasonable business precaution to ensure continuity in the delivery of service in the case of payment delays. A provider agency must be able to continue in business, meeting all rule requirements, between the time CCP services are initially provided and the time reimbursement is received from the Illinois Comptroller. It could potentially take 90 calendar days or more for a payment cycle depending on fund availability in the State Treasury. Understanding the payment cycle is a matter of particular importance to new provider agencies that, for an initial period, will have no State reimbursement to cover required expenditures.
How should an applicant agency calculate 90 days of operating expenses?
The Department recommends that the agency base the amount needed on its business plan and past experiences with the State of Illinois or other units of government.
Are CCP provider agencies required to be licensed as a home service agency by the Illinois Department of Public Health?
No. CCP provider agencies for in-home services that operate exclusively under this program are exempt from the licensing requirement imposed upon home service agencies under the Home Health, Home Services, and Home Nursing Agency Licensing Act [see 210 ILCS 55]. If an agency only intends to provide CCP service, it must only meet certification requirements set by the Department. However, most home service agencies will also provide services to non-CCP clients in which case a license must also be obtained from the Illinois Department of Public Health.
Are any other factors about general business practices considered by the Department in determining the qualifications of an applicant agency?
Yes. Other factors which may influence the certification decision include: pending or current Departmental contract action for failure to adhere to Provider Agreement requirements, including a history of non-compliance; notification by another governmental entity of similar contract actions or non-compliance; legal notification of financial insolvency, criminal indictment or conviction, or other legal issues which, in the opinion of the Department, would make the award of a contract contrary to the best interests of the state; or a contract award is not in the best interests of the program. For more information regarding administrative requirements for certification, refer to the CCP rules, Section 240.1505(a)(7).
What is a CCP geographic service area?
A CCP geographic area varies by region:
The goal of the Department is for a certified provider agency to serve an entire CCP geographic area, if possible.
What are possible reasons for adjustment of the geographic service area requirement?
Adjustment of the geographic service area might be permitted to assure that:
Adjustment will be allowed in only limited circumstances. It is not intended for routine use that might lead to "cherry-picking" or make it more difficult to address needs in hard to serve areas in a cost-effective manner.
How does Section 240.1505(a)(2) of the CCP rules apply for adjustment of the geographic service area requirement if an applicant agency currently serves areas in several PSAs instead of an entire county, sub-area or township?
A discretionary adjustment of the geographic service area requirement would only be made if the applicant agency meets one of the specified exceptions set forth in Section 240.1505(a)(2) of the CCP rules. If not, then the Department will expect the applicant agency to serve an entire CCP geographic service area in order to be certified under the program.
Will a current CCP service provider be allowed to expand into any new geographic service areas if it there is a pending contract action?
Is a minimum amount of experience required to be a CCP provider?
Section 240.1505(a)(6) of the CCP rules requires the following service-related experience for the different types of provider agencies:
The Department may adjust these requirements on an individual applicant basis.
Why is experience necessary?
Actual service experience is useful in predicting the ability to meet the various certification standards for the CCP. Also, it is in the best interests of clients and CCP to certify provider agencies with ongoing business operations to minimize disruption of service continuity and to maximize the delivery of services by certified providers throughout the entire State of Illinois as soon as possible.
Is there any time limit on whether experience is relevant?
There is no specific time limit in Section 240.1505(a)(6) of the CCP rules. However, experience that is not current will not be useful in predicting the ability to meet the various certification standards for CCP.
Inclusion of a service adjustment for experience is intended to establish a fair protocol for exceptions, but permitting exceptions remains a matter of discretion and reflects a balancing effort on the part of the Department to encourage small business development. The Department recognizes need to review other indicators for success, especially since situations arise with some frequency where there is an organization change in private business. Service adjustments for experience are not intended to become the norm under CCP.
Are there any examples of services that are comparable to CCP services?
The Department believes that the following services will be comparable to CCP services:
Could the Department provide some examples of when adjustments to the experience requirement, other than for current accreditation, might be allowed by the Department?
Each request for adjustment of the experience requirement will be determined on its own merits and factual circumstances. As stated in Section 240.1505(a)(6)(B)(ii) of the CCP rules, the Department allows adjustments only when it is in the best interests of CCP and when the health, safety and welfare of CCP clients and the quality of services provided will not be adversely affected.
The following are examples of situations in which the Department might allow an adjustment to the experience requirement:
What specific job descriptions should be included in the certification packet?
Specific job descriptions should be included for all positions that provide service to CCP clients.
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Can a transportation area be smaller than the contract coverage area?
No. The Adult Day Service agency must provide transportation to the entire contract coverage area specified in the application.
Does an adult day service agency have to provide transportation outside of the contract area?
No. Transportation is not required for clients in an outlying service area. For areas outside the agency’s service area, families may transport or arrange transportation for clients to come to the site.
How does service availability expansion work?
Service availability expansion is authorized under Section 240.1570 in the CCP rules. It occurs when a client is allowed access to CCP services in a geographic service area in which the client does not reside. Possible reasons for service expansion for a client in an outlying service area include: a determination by the CCU that the needs of the client may best be served by a provider in an outlying service area; the geographic area in which the client resides does not have a provider of the needed services; or services may be provided more conveniently or appropriately by a CCP provider in an outlying service area.
How are the Case Coordination Units (CCU) notified that an adult day service site can serve their area?
The Department notifies the CCU in the Adult Day Service (ADS) site’s contractual service area and forwards a copy of the Service Specific Application for that site. The Department does not notify CCUs of the availability of ADS sites in contiguous areas to the CCU service area. While the Department maintains a list of all ADS providers on its website, an certified ADS provider might want to contact CCUs in contiguous areas directly to advise them of service availability as long as transportation can be arranged by the family or through other means.
What is a reasonable amount of time that clients can be on the transport vehicle?
The amount of time that is reasonable for client transportation will vary. Several factors to be considered include: whether the service is appropriate, compliance with limits set in an individual plan of care based on client health, handling traffic in the geographic area served, and the location of the client’s home within the area. The transit time should be as short as possible, allowing the client to spend as much time as possible receiving services at the adult day service site. While transportation is an important consideration, it is only a means to an end for adult day service.
Does an adult day service agency have to provide its own transportation?
Not necessarily. Although a provider agency is responsible for making sure clients in the geographic service area have transportation to and from the adult day service site, the agency may either provide transport itself, subcontract with another entity to transport clients, or make arrangements for the provision of transportation if other service options are available in the geographic service area, such as a Human Service Transportation Plan (HSTP) Organization.
If the agency is unable to locate any transportation subcontractors in the geographic service area, the Area Agency on Aging may have additional resources for help.
However, if the agency is unable to subcontract or otherwise arrange for transportation of all CCP clients to and from the adult day service site, the agency must provide the transportation.
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