In 2018 COF Training Services, Inc. proudly celebrates its 50th anniversary of providing services to people who are intellectually and/or developmentally disabled living in Coffey County and Osage County and Franklin County, Kansas.
Major services provided by COF Training Services, Inc. include Targeted Case Management Services, Day and Residential Services, and Working Healthy / WORK / Independent Living Counseling (ILC). Additional services and programs are described in this website.
Medicaid is a federal program. Each of the 50 States enters into its own partnership with the Medicaid program. Funding of the Medicaid program is shared between the federal government and each State. Medicaid exists to ensure that people who are poor and/or aged and/or disabled receive needed care.
COF is a not-for-profit enterprise with 501(C) 3 tax exempt status.It is important to understand that not-for-profit does not equate to: "for-loss"or to: ”just break-even."As with any other business enterprise, not-for-profit enterprises must have a profit margin to continue to operate their business enterprises. However, not-for-profit enterprises do not operate for the purpose of making a profit. There are no owners. There are no shareholders. The not-for-profit exists for a charitable purpose. COF Training Services was formed for the charitable purpose of providing supports and services to people with disabilities, who without such supports and services, would be unable to survive or would only be able survive with extraordinary difficulties. Any and all of COF's profits are held for the people receiving services from COF. Additionally, at COF, there is an unpaid, volunteer Board of Directors that ensures the proper use of COF's finances and other resources.
Reliance on government funding as the primary source of funding is precarious. For example, COF and other organizations like it provided services for approximately 10 years until 2017 without any funding increases. Cost of doing business, though, continued to increase during those 10 years. Funding is subject to political whims and woes and competing budgetary issues in the State's budget.
For these reasons COF Training Services created Friends of COF in 2011. Friends of COF is COF Training Services' fundraising arm. Donations of money, assets, and talents are important to the continuing successful operation of COF. Please consider joining Friends of COF &/or contributing as you can.
Entering an Era of Change
Historically, COF has provided the array of services that are typically provided by the hundreds of other organizations of its type across the nation. However, the field of providing services to people with intellectual and/or developmental disabilities is in a new era of tremendous changes that have been occurring over the past few years. These changes are affecting how services are delivered and funded.
New Federal Regulations, combined with a series of class action lawsuits that are being filed against individual States, are causing COF Training Services, Inc. to initiate changes. The implications of the changes that will be coming and those that have already occurred are profound for all organizations that provide services and for all of the people who receive those services. It is still too early to be able to foresee the full ramifications of these changes.
This website explains COF's responses to two main change mandates: the CMS' Final/Settings Rule and the Workforce Innovation and Opportunities Act, or WIOA. Additionally, there are other forces that are converging at the same time to contribute to the causes of these impending changes. Interested readers are encouraged to explore further the information that is widely available on the internet regarding:
- The Olmstead Supreme Court Decision
- CMS' Final/Settings Rule
- Workforce Innovation and Opportunities Act (WIOA)
Numerous class action lawsuits have been filed against various states by users of services that are funded by Medicaid / HCBS &/or in conjunction with the United States Department of Justice. Ramifications of these issues are not necessarily limited to the boundaries of the States in which they are filed. And, this method of achieving change is spreading from one state to another and another. Many believe that Kansas is ripe for a class action lawsuit of this nature. The underlying theme of all of these class actions suits is essentially the same. Individuals who need services are either not getting services or the funding is inadequate or the people who need the services are not being provided with the types of services they want or need or the services that are provided have effect of segregating and isolating people who rely on these services. Very particularly the aforementioned regulatory changes and these class action lawsuits are calling for a marked shift in the way services have been funded and delivered. Class action suits to improve services have been filed in:
- Ohio regarding waiting lists
- Illinois regarding changes in disability
- Florida regarding changes in disability
- Georgia regarding rate setting
- Pennsylvania regarding rate setting
- New Mexico regarding people previously in state institutions
- Arizona regarding schools
- Connecticut regarding schools
- Tennessee regarding state hospital enrollment
- Delaware regarding lack of payments for contracts
- Oklahoma regarding child welfare
- Washington regarding child welfare
- Oregon regarding access to integrated employment
- Tennessee regarding sanctions and recoupments
Virginia regarding Department of Justice consent
- Information pertaining to the particulars of these lawsuits is readily available on the internet.
Provider-Centric vs. Person-Centered Models
The underlying theme of all these changes is to ensure that people with intellectual and/or developmental disabilities are fully integrated into society and have as much personal control of their lives as is possible. This new era that we are in is causing a gradual shift away from current service delivery systems which have historically provided- all the services that a person with intellectual and/or developmental disabilities might need under "one roof" or within a single agency. All services are provided by one single organization known as a Community Services Provider (CSP). This long-standing service delivery model is often referred to as the "provider-centric model.”
Among the unintended effects of this "provider-centric model" have been:
- People with intellectual and/or developmental disabilities have inadvertently been segregated from people who are not disabled. These people often live in "group homes"owned by the same company which provides the services, and often attend "sheltered workshops", again owned by the service-provision company. The same Community Service Provider (CSP) owns and operates the transportation vehicles and determines the schedule of use of these vehicles.
- All of the people with I/DD who reside in "groups"in the homes that are owned and operated by the CSP are transported as a "group" of people with I/DD in vehicles that are owned and operated by the CSP to the day center/sheltered workshop that is owned and operated by the very same CSP. Transportation and programming is based upon the scheduling and operational needs of the CSP rather than upon individual choice.
- A single organization that provides essential services to people with intellectual and/or developmental disabilities often has too much control over multiple facets of the lives of the people for whom those services are provided.
- Services in the provider-centric model easily become more "setting-centered"and "group-centered" than "person-centered".
Kancare and Managed Care Organizations (MCOs)
Providers of services to people with intellectual and/or developmental disabilities in the State of Kansas have an added complication and challenge. The State of Kansas rendered almost all its Medicaid funding to three extremely large insurance companies, referred to as MCOs. These MCO organizations trade and sell shares on the major stock exchanges. Consequently, the MCOs are expected to produce strong profits for their shareholders. This model is known as Kancare. Previously, organizations like COF dealt with state workers for the State of Kansas' Department of Aging and Disabilities Services, generally referred to as KDADS. Under the state's KDADS' auspices, there was no profit motive involved in providing funding for services for persons with disabilities. By turning control of its Medicaid funding over to MCOs, though, the State of Kansas hopes to control the escalating costs of Medicaid. This transfer of Medicaid funding to MCOs has worked out well for the profit-motivated MCOs whose combined profits have been $400,000,000 per year for each of the past couple of years. Since this approach to funding is so new, there is not enough data yet to ascertain whether it has been adequate and beneficial to people who rely on Medicaid for services and supports.
Medicaid: Evaluating KanCare’s Effect on the State’s Medicaid Program
With Kancare, in conjunction with the previously mentioned changes, astonishing changes are being imposed upon organizations like COF as to how they are now being expected to provide services to people with intellectual and/or developmental disabilities. There is, however, no "blueprint"provided which would serve as a guideline to ensure greater integration and individual choice.
At COF we are trying, in good faith, to make required changes as best as we can and in a timely manner. We understand that changes, especially significant changes in a short period of time, that are being imposed by a multitude of outside sources can be difficult to understand.
COF'S Current Services and Recent Changes
The following information is an explanation of and reason for the changes COF has made and/or is in the process of implementing.
CDDOs and CSPs
*Key Change #1*
COF separated its CDDO from its CSP
Until February of 2015 COF Training Services was both a Community Developmental Disability Organization (CDDO) and a Community Services Provider (CSP). Now COF Training Services is a Community Services Provider (CSP). It is no longer a Community Developmental Disability Organization (CDDO).
In Kansas, the terms Community Developmental Disability Organization (CDDO) and Community Service Provider (CSP) are often incorrectly used interchangeably which understandably lends itself to some confusion. The functions and purposes of a CDDO and a CSP are wholly separate. However, in Kansas many organizations providing services to persons with intellectual and/or developmental disabilities such as COF Training Services, Inc. serve in a dual capacity as both a CDDO and as a CSP.
COF Training Services is what is commonly referred to as a Community Service Provider (CSP). What this means is that COF Training Services provides services to people who, without the types of services provided by COF, would be unable to survive on their own or would otherwise have extraordinary difficulties in their daily lives.
Until February of 2015 COF served in a dual capacity as both a Community Service Provider (CSP) and as a Community Developmental Disability Organization (CDDO).
Information about the CDDO:
The primary functions of a CDDO are:
- to determine whether a person meets the criteria to be eligible to receive services from a CSP;
- to facilitate an impartial team process to determine the amount of funding that will be needed to provide services. This is done through the assessment tool that is known as "BASIS”;
- to facilitate an impartial and unbiased choice process that enables an individual who is eligible for services to make an informed choice regarding which provider(s) they would to use for their services;
- to provide fair and impartial quality assurance oversight of the provision of services that are provided by the Community Service Providers (CSPs) in their catchment area.
Many changes are being imposed upon Community Services Providers (CSP) by the Centers for Medicaid and Medicare Services' (CMS) Final/Settings Rule. CMS' Final/Settings Rule was introduced in 2014. It pertains to how services that are funded by the Home and Community Based Services (HCBS) are delivered by Community Service Providers (CSPs) such as COF Training Services, Inc. Among the underlying themes of CMS' Final/Settings Rule is to eliminate any potential conflicts of interest that CSPs have in the way that they provide services.
When a single organization serves in the dual capacity of being both a CSP and a CDDO, there is clear potential for the person receiving services to experience a conflict of interest within each of the primary functions of the CDDO that are previously listed. For example:
- the organization that provides services to individuals in need of services (CSPs) should not also be determining the eligibility of the individuals (a CDDO function),
- nor should the CSP determine the amount of funding that the individual receives for services, (a CDDO function),
- nor should the CSP determine which CSP they should choose (unbiased presentation of choice options should be presented by the CDDO),
- nor should the CDDO, under the CSPs services umbrella be providing quality assurance oversight of itself.
COF voluntarily and proactively chose to take the step of breaking-off its CDDO from under COF's service umbrella. In February of 2015, COF chose to break off the CDDO component of its organization and give it to a wholly separate not-for-profit entity. What was previously COF's CDDO program is now the CDDO of East Central Kansas Area Agency on Aging (ECKAAA). This was a logical fit because part of ECKAAA's function is to determine eligibility for other types of social services besides services for those living with intellectual/developmental disabilities.
There are many other organizations like COF that serve in the dual capacity of CSP and CDDO. Most organizations are choosing to wait as long as possible until they are absolutely sure that they will be required by CMS to separate their CDDO from their CSP. This is a reasonable thing to do because full implementation of CMS's Final/Settings Rule is a years-long process of 5 to 7 years beginning in 2014. Every organization is different. Each has to choose its own course on its own time scale as to how / when to respond to the many changes that are being imposed upon our field. To the extent that it is reasonable to do so, COF has been proactive in its response to CMS' Final/Settings Rule. Separating its CDDO services from under the COF services umbrella is one example of several key changes that COF has implemented. COF Training Services, Inc. is active in its support of eliminating as many potential conflicts of interests as possible when providing services to the individuals who choose COF as their provider.
COF's Licensed Services
A Community Services Provider cannot provide services unless it is licensed to do so. COF is licensed by the Kansas Department of Aging and Disabilities (KDADS) to provide:
- Targeted Case Management (TCM) services
- Homes that have 24-hour shift staffing supports
- Homes that have intermittent staffing supports
- People who live independently in their own residences
- IEE (Integrated Employment Enterprises)
- Thriftopia, a resale shop
- Burlington and Osage City workshop employment
- Community based employment
- Working Healthy / WORK / Independent Living Counseling (ILC)
- Financial Management Services (FMS)
Additional services provided by COF include:
- Transportation Services
Nursing supports & liaison Services
*Key Change #2*
Changes in Nursing Services
COF continues to provide nursing supports and services following all state and Federal regulations. COF continues to employ 3 fulltime nurses. Additionally, COF contracts with Midland Care for additional nursing services and oversight. COF staff are trained and supervised by licensed, professional nursing staff to be certified medication administration aides. COF staff are also trained in First Aid, CPR, and emergency response techniques to ensure the health and safety of all individuals receiving services. Individuals receiving services from COF have access to the same community health services to which every citizen has access: physicians’ offices, emergency rooms, and local hospitals. COF staff works in conjunction with its nurses and Midland Care to assess the illness or emergency, and to act in the individuals’ best interests. Before CMS' Final/Settings Rule most organizations like COF housed "mini-clinics" at which nursing services were provided instead of accessing community services as every non-disabled person does.
*Key Change #3*
Change in Payee Services
In keeping with its attempts to be proactive in its responses to CMS' Final/Settings Rule, COF discontinued its Payee Services as of January 2018. CMS' Final/Settings Rule deemed it to be an issue of:
COF ensured that all users of its payee services were given an informed choice to enable them to choose from among other Companies that provide Payee Services.
Within its various licensed service options, COF provides services to approximately 400 people. Historically, most of these people have been people with intellectual and/or developmental disabilities. In the past few years, though, COF has been diversifying its programs to provide services to people with other types of disabilities with a special emphasis on employment.
COF's primary service area has been Coffey County, Osage County and Franklin County. COF is currently in the process of beginning (in 2018) to gradually expand its services into neighboring Lyon County and Shawnee County. This step is being done primarily for the purpose of increasing employment opportunities which are very difficult to find in the very rural counties of Osage and Coffey.
Targeted Case Management (TCM)
COF is licensed by the Kansas Department on Aging and Disabilities (KDADS) to provide Targeted Case Management Services (TCM). Targeted Case Management Services are provided to people with intellectual and/or developmental disabilities in the following eight counties: Coffey; Osage; Franklin; Lyon; Wabaunsee; Chase; Morris; and Shawnee.
Main functions of the Targeted Case Managers:
- Person Centered Services Plan (PCSP)
Every person who receives services from COF is required by regulation to have "a plan." This plan is a personal plan that is unique and specific to each individual. This plan is called a Person-Centered Service Plan (PCSP). Within this PCSP, the person receiving services lists his or her needs, desires and wishes as pertains to his or her life choices. The Targeted Case Managers are primarily responsible for assuming the lead role in the development and the writing of this plan. The maintenance of this plan as a team process. The Community Service Provider (CSP) such as trained staff working for COF Training Services, Inc. implements this plan and uses this plan as tool or guide for providing services. This division of writing the plan (TCM) and implementing the plan (a CSP such as COF Training Services) is the fundamental difference of roles between the TCM and the CSP.
Team members are individually chosen by and/or selected based on the needs and wishes of the person for whom the PCSP is being written. The PSCP is indicative of the wishes, the choices, and the needs of the individual for whom it is written. The PCSP should reflect the person's "preferred lifestyle”.
A team meeting must be convened by the TCM at least once a year. This meeting occurs at least annually so that the individual's PCSP can be updated and revised in accordance with the person's changing needs and wishes. A team meeting can be convened more often than once a year if it is necessary to do so. Regardless of how often a team meeting is convened and a PCSP is revised, it must always be based on the needs and wishes of the individual receiving services. Also, the TCM must always be involved.
- Linkage of Services
In addition to its responsibilities for the Person-Centered Service Plan (PCSP), the Targeted Case Manager/TCM is responsible for "linking"the person to whatever social or medical services that individual might want or need. The TCM does not provide the services; rather, the TCM is the liaison between the individual and those entities that provide the services.
In linking the individual to various social and medical services the TCM should be impartial. So, for example, a person who uses COF's TCM services may feel free to choose a provider, other than COF, to provide their residential &/or day &/or employment services. Ensuring this impartiality is one of the most important themes of the array of regulatory changes confronting organizations like COF.
CMS' Final/Settings Rule: Reasons for changes in Targeted Case Management Services
As with the CDDO, the TCM cannot be in the dual role of being a Community Service Provider (CSP) while providing Targeted Case Management services at the same time. As with the CDDO, this too, is deemed to be a conflict of interest by the Centers for Medicaid and Medicare Services (CMS) in its Final/Settings Rule. CMS' Final / Settings Rule states that it is a conflict of interest for the Community Service Provider (CSP) to also be in control of the PCSP and of the choices that are built into the plan. If the TCM is part of the same organization as the CSP, the TCM may feel unduly pressured to persuade the individual for whom the PSCP is being written to make choices that are favorable to the CSP.
Unlike what COF was able to do with its CDDO (turning it over to a separate company), there is no natural-tie to any other not-for-profit organization to which COF's TCM-unit could be moved. Additionally, the funding for TCM is not such that COF could break it off as a stand-alone business unit.
*Key Change #4*
Changes in Targeted Case Management
COF has taken the first of two steps to eliminate potential conflicts of interest between the CSP and the TCM. As of October, 2017 the Director of Targeted Case Management began reporting to a committee of COF's Board of Directors instead of directly reporting to the CEO. This TCM Board committee consists of parents of people who use these TCM services. COF's CEO no longer has any oversight of Targeted Case Management Services. This step satisfies the intent of CMS' Final/Settings Rule.
The second step will occur if/when COF eventually establishes a separate TCM company that will have a separate Board of its own. This company is already registered with the State of Kansas as Kansas Case Management. As stated, this TCM will be a separate Company, but it will maintain a relationship with COF. COF will not take this step until/unless it is required to do so by the state govenment.
The Director of Targeted Case Management (TCM) is Jennifer Star. Her contact information is: email@example.com / 785-893-2111. Feel free to contact Jennifer with any questions or concerns that you might have about TCM.
Residential Services and Day / (Employment) Services
COF is licensed by the Kansas Department on Aging and Disabilities (KDADS) to provide Residential Services. COF is also licensed to provide Day Services. For the past 50 years COF has been providing Residential Services and Day Services in Coffey County and Osage County and Franklin County.
In 2019 COF will be trying to gradually expand these services into the neighboring Counties of Lyon and Shawnee. As stated previously, this step is being done primarily for the purpose of increasing employment opportunities for persons receiving services from COF-which are very difficult to find in the very rural counties of Osage and Coffey. The person who oversees COF's Residential Services and Day Services is its Director of Operations, Patrick Gardner. His contact information is firstname.lastname@example.org / 620-364-6943. Feel free to contact Patrick with any questions or concerns that you might have about COF's Residential Services and/or COF's Day / Employment Services. Also, contact Patrick if you would like to have a tour of COF.
- Residential Services
It is important to repeat what has previously been stated: in February of 2015 COF voluntarily separated from its CDDO in order to avoid potential conflict of interest. Similarly, in October of 2017 COF began the first phase of the process to separate its TCM from under the COF umbrella of services. In both cases, this separation was initiated by COF in response to the new federal regulations that came out in 2014 from the Centers for Medicaid and Medicare Services (CMS). These regulations are commonly referred to as CMS' Final Rule or CMS' Settings Rule. The breaking off of these two components of COF was because in both cases CMS' Final/Settings Rule deems it be a conflict of interest for any single organization to have so much control over the lives of the people for whom it provides services.
COF is now explicitly a Community Service Provider (CSP) without these two programs (CDDO and TCM). Again, these steps have been taken in response to CMS' Final/Settings Rule. There are many additional far-reaching ramifications of CMS' Final/Settings Rule, other new federal regulations and various class action law suit settlements in several states across the country.
- Residential Settings/Property Ownership
Until August of 2016 COF had ownership control of a number of residential properties. These included the following:
- in Ottawa: four 6-to-8-person group homes; two 3-person group homes; one 16-unit apartment complex
- in Burlington: two 6-to-8-person group homes; three 3-person group homes
- in Osage City: two 6-to-8-person group homes; one 3-person group homes.
Approximately 90 people with intellectual and/or developmental disabilities reside in these "settings."The word "settings"is a key word to keep in mind. This is because in CMS' Final/Settings Rule the fundamental question is:
- "Does the "setting"at which a person receives residential services and/or day services have the effect of:
- isolating that person from people who are not disabled and/or
- keeping these individuals from accessing any services or activities in the communities in which they live and/or use that any of their non-disabled fellow citizens use?
These residential "settings"or properties operate under the auspices of the federal Housing and Urban Development (HUD). Rents are low and are affordable because they are subsidized for people who have low incomes. Most of the people who have intellectual and/or developmental disabilities and receive services from COF have low incomes. They benefit tremendously from having access to this type of housing. COF tries to help the people for whom it provides residential services to access government subsidized housing, without regard to who has ownership control of the properties.
*Key Change #5*
Change in Ownership of Residential Properties
Regulations that came out in 2014 known as CMS' Final/Settings Rule deems it is a conflict of interest when the organization that owns the residential properties (such as COF Training Services, Inc.) also provides residential services to the people it serves in those same properties it owns. Concern is that the organization providing the services will have too much control over the people for whom it provides services, and those individuals' choice opportunities will be diminished. CMS' Final/Settings Rule assumes that the opportunity to make choices of where to live will be unduly limited because the person receiving services might feel compelled to live in the properties owned by the provider of their services (the CSP). This is a repeated theme throughout CMS' Final/Settings Rule.
In order to comply with CMS' Final / Settings Rule, in August of 2016 COF rendered ownership control of these properties to a separate entity operating under a separate Board of Directors.
Not that anyone who received services from COF was ever compelled to live in properties previously owned by COF, but now COF no longer has ownership control of these properties.
24-Hour vs. Intermittent Residential Services
There are two categories of Residential Services provided by COF. Some people need 24-hour supervision and care. Others do not need round-the-clock supervision and care. A person using COF's Residential Services receives either 24-hour care or intermittent care.
The priorities of COF's Residential Services are:
- to ensure the health and safety of the people who are dependent upon those services;
- to ensure that these individuals are being supported in living the lifestyle of their choices to greatest extent that it is possible to do so;
- to maximize their opportunities to be fully integrated into the community in which they live.
The types and amounts of care that each person needs are spelled out in the Person Centered Support Plan (PCSP). The PCSP is a document developed by the individual and his or her guardian, if there has been one appointed, in conjunction with a team of individuals of their choice under the guidance of Targeted Case Management (TCM). The PCSP is the document or tool by which the Community Service Provider (CSP) such as COF knows what types and amounts of services the individual needs and wants.
Examples of Residential Services that people in need of 24-hour supervision and care might need include:
- meals – helping with determining a menu, shopping for needed items, preparing the food, helping with feeding themselves, storing leftovers, cleaning up after meals, etc.
- grooming and hygiene – helping with some or all aspects of caring for our needs, including helping with toileting, bathing, grooming, picking out clothes, dressing, etc.
- transportation – ensuring that people who receive services get to and from their day program site, their work site, their medical appointments, hair care appointments, other community activities, etc.
- participating in community activities-ensuring that ample opportunities are provided to integrate with fellow citizens who are not disabled, ensuring people receiving services can fully participate in their communities by eating out, shopping, participating in community events, attending their church of choice, enjoying parks, exploring recreational sites, attending sporting events, etc.
*Key Change #6*
COF Must Change Some of the Ways it Delivers 24-Hour Residential Services
The impact of CMS' Final / Setting Rule on how services are provided in24-hour residential "settings" are significant.
Examples of Residential Services that a person in need of intermittent care might choose include:
- transportation – most people with intellectual and/or developmental disabilities do not drive. In rural areas there is no public transportation. COF transports people receiving services to and from: stores, worksites, medical appointments; on community outings, to participate in volunteer services, etc.
- basic living supports –prompts and supports may be needed to keep themselves or their homes clean; in dealing with life situations such as paying bills, resolving relationship, landlord, or work ethic problems; maintaining a healthy lifestyle, taking medications as prescribed, etc.
Without these types of ongoing intermittent supports and services, many of these individuals would need to live in more expensive and more restrictive residential settings with 24-hour care.
COF strongly encourages the people who use COF's Residential Services and/or COF's Day Services to be active participants in their community through volunteering.
Volunteering and working are two of the surest ways to ensure that people with intellectual and/or developmental disabilities are included in and integrated into the communities in which they live. Some people, though, prefer not to work, volunteer or attend day services. The State of Kansas allows for this option if it is deemed to be the persons "preferred lifestyle"and if it reflected accordingly in their PCSP.
People receiving services from COF are strongly encouraged to maintain jobs.
Most people who use COF's Residential Services also use COF's Day Services. Additionally, there are many others who use COF's Day Services, but who do not need COF's Residential Services because they may still live at home with family members. For people who use both Residential and Day Services, these services are blended into the persons' daily routines as much as it is feasible to do so.
Generally speaking, CSPs like COF Training Services, Inc. provide Day Services in buildings ("settings”). These "settings"exist for no other purpose than to provide a space for people with I/DD to receive services from paid staff. There are three broad categories of day services:
- a sheltered workshop-in which people with I/DD perform relatively simple and routine assembly/packaging types of work. These types of jobs are found by the CSP such as COF by trying to persuade manufacturers to sub-contract/outsource some of their jobs to sheltered workshops to provide employment for people with I/DD. Finding jobs for people who work in sheltered workshops is not easy. Manufacturers have no reason to outsource their work unless it saves them money. Because of their disability, though, most people with I/DD cannot produce enough to earn minimum wage or higher. If people with disabilities working in sheltered workshops were capable of producing at a competitive rate, they would probably be able to work in the actual manufacturing plant instead of in the sheltered workshop. Sheltered workshops pay people with I/DD by the "piece"produced instead of by the "hour." Piece rate pay is a legal practice in Sheltered Workshops for people with I/DD.
- a day-center-in which people with I/DD might participate in recreational types of activities and/or educational/training types of activities. Educational/training types of activities can include pre-vocational training geared towards helping the individual acquire the skills to find and maintain a job;
- community jobs-most organizations like COF try to find employment opportunities with employers based in the community. These types of jobs are ideal because they provide the competitive wages and the integrated work setting that is now being expected. In rural areas, though, it is difficult to find available jobs.
*Key Change #7*
COF Must Change Some of the Ways It Delivers Day/Employment Services
CMS' Final/Settings Rule deems the historic "provider centric model"to be unsuitable. By definition, sheltered workshops and day centers are buildings, or "settings"that have the effect of isolating people with I/DD from people who not disabled. 24-hour care residential "settings,"day center "settings"and sheltered workshop "settings"are "settings"at which people with I/DD are grouped together because of a disability that they share in common. An unintended consequence of the "provider centric model"is that people who use the services of the CSPs like COF must adapt to the operational and scheduling needs of the CSP. CMS' Final/Settings Rule is trying to change that. Ideally, it is the CSP, not the individual, that should have to adapt to the needs of the people it serves. For example, the CSP like COF should try to deliver the services that are wanted and needed at the times and locations that the individual prefers.
Transitioning into these required changes is not easy. That is why CMS is allowing a five-to-seven-year time window to complete the necessary changes. Trying to implement these changes in rural areas is more difficult than it is to do in more densely populated areas because there are far less employment opportunities for people with I/DD and far less opportunities for integrated activities. There are two additional significant factors that compound the difficulties for fully implementing these changes:
- CMS' Final/Settings Rule and WIOA expect the CSPs such as COF Training Services, Inc. to be trying to find employment for all of the people it serves. Employment is expected to be integrated in "settings"at which the individual with I/DD is working with and interacting with as many people who are non-disabled as any other non-disabled person does in the course of their work day. And, they expect that the person with I/DD should be paid the same competitive wages and benefits as any other non-disabled person at the place of employment is paid.
- Kancare ultimately may have the effect of decreasing the revenues that CSPs rely upon to provide services while at the same time CMS' Final Rule is driving the costs of services up by trying to unravel the relatively cost-efficient "provider-centric model." This is the convergence of the proverbial perfect storm for CSPs such as COF Training Services, Inc.
COF has implemented or is in the process implementing the following measures to come into compliance with CMS' Final/Settings Rule and WIOA for its Day and Employment Services:
IEE/Integrated Employment Enterprises:
Visit IEE's website: www.iee-inc.org
COF's former sheltered workshop space in Ottawa has been converted into a business model that provides work at competitive wages/benefits in a setting that is fully integrated. Integrated Employment Enterprises (IEE) is the name of this business. People with I/DD work side-by-side with people who are non-disabled or who are otherwise disabled. Integrated Employment Enterprises (IEE) is an independent business. It began doing business in January of 2016. It does not receive any government funding. It has 509 (a) 3 tax exempt status. It was established as a Type III functionally integrated supporting organization (FISO) to COF which is the tax exempt 501(c) 3 supported organization. IEE has its own Board of Directors. COF's Board of Directors appoints two of those members.
- Chris Patton - COF CEO (COF Board apointee)
- Lisa Johnson - Ransom Memorial Hospital legal council (COF Board apointee)
- Harold Wingert - President of Sun Flower Consulting
- Jay Terry - Retired owner of a consulting company / parent
- Bobby Combs - National Sales Manager at Truck Accessories Group, LLC
- Craig Evans is the President of IEE. He reports to IEE's Board of Directors. His contact information is: email@example.com / 785-248-6207. Feel free to contact Craig with any questions or concerns that you may have about IEE.
- As of June, 2018 IEE employs 49 people.
- IEE does light manufacturing, assembly, and kitting work. This is done at IEE's manufacturing plant in Ottawa &/or at the manufacturer's site depending on the needs of the manufacturer. Examples of businesses for which IEE has recently performed or is currently performing work for includes:
- Walmart Distribution Center, Ottawa
- Sorted shipping boxes
- Kalmar Trucking (Manufacturing), Ottawa
- Special projects as needed
- Systemair (Manufacturing), Lenexa
- Assemble & pack dampers
- Stouse Printing, Gardner
- Packaging & kitting - special projects as needed
- Rockwell Collins, Lenexa
- Assemble and ship commercial airline passenger masks
- Assemble and ship small part components
- Orbis Plastics, Osage City
- Labeled & palatalized Plastic Totes
- Charloma Plastics, Burlington
- Cleaned, labeled, and packaged vent hoods
- KGP, New Century
- Assemble & ship packaging boxes
- Sort and clean cable wires and cords
- CFS West Holdings, New Century
- Assemble and ship floor displays for Mayonnaise
- Hasty Awards, Ottawa
- Assemble packaging boxes
- Project Lydia, Lawrence
- Kit and package of soaps, lotions, bracelets
- Logo Light House, Kansas City
- Kit and package small decorative / advertising items
- Fastenal, Ottawa
- Kit and packaging of small tooling and fixtures
- Buena Vista, Ottawa
- Grows trees and shrubs for wholesale distribution
- Flint Hills Beverage, Osage City
- Disposal of outdated beer
A thrift store in Ottawa, Kansas, providing work opportunities for persons receiving services from COF.
- COF Training Services, Inc. opened a large thrift store in December of 2016. It is called Thriftopia. It is a not-for-profit limited liability company (LLC). It is located in a strip mall among a larger number of other businesses on the south side of Ottawa, Kansas.
- Thriftopia provides part time paid prevocational training employment for approximately 55 people who are intellectually and/or developmentally disabled. This employment is in an integrated setting.
- The goal of thriftopia is to help individuals with intellectual and/or developmental disabilities aqcuire the skills and competancies needed to gain competitive and integrated employment with employers who are not affiliated with COF.
- The other goal of Thriftopia is to provide employment opportunities for those who otherwise have never been able to work in an integrated setting.
- People from Ottawa and surrounding communities enjoy shopping at Thriftopia's store, located at 2210 South Princeton Drive, Ottawa, KS 66067.
- Tax-deductible donations are dropped off at Thriftopia's south side receiving area.
- Thriftopia activities may be followed on Facebook
IEE and Thriftopia are examples of actions that COF has taken to actually create jobs. This is necessary in rural areas where employment opportunities that people with I/DD are capable of filling are not always readily available in sufficient numbers.
COF continues to employ 60 people with I/DD in its sheltered workshop "settings"in Burlington and Osage City, Kansas. Even though CMS' Final/Settings Rule and WIOA deem sheltered workshop settings to be undesirable options, COF will continue use this option until it can find the more desirable competitive/integrated employment opportunities that CMS' Final/Settings Rule and WIOA will eventually be requiring in the future.
These individuals perform light manufacturing, assembly, packaging, kitting work that has been outsourced to them. They only do paid work. They do not engage in unpaid activities.
It is important to bear in mind that many people who use COF's service and/or their guardians still prefer this Sheltered Workshop option, regardless of what CMS' Final/Settings Rule and WIOA deem suitable. The job status of each of the individuals working in COF's Sheltered Workshop settings is reviewed regularly, and potential employment options are reviewed and pursued. COF's goal is to ensure that competitive and integrated employment opportunities are found and that individualized supports are provided for everybody who wants that employment option.
COF facilitates and helps people to maintain employment for approximately 15 to 20 people in various community-based settings including, but not limited to:
- Spring Creek Farms (organic farming for wholesale distribution) in Baldwin City
- Wolf Creek Lodge in Burlington
- Republican Newspaper in Burlington
- Hoovers Thriftway Grocery Store in Burlington
- Crow / Moddie Chevy & Ford Dealerships in Burlington
- The Recreation Center in Burlington
- Countertop Trends (manufacturing) in Gridley
- Osage City Nursing Homes in Osage City
- Theel Plumbing in Osage City
- Osage Family Medical Care in Osage City
- Jerry's Thriftway Grocery Store in Osage City
- Ottawa Herald (newspaper) in Ottawa
- Comfort Inn in Ottawa
- Walgreens in Ottawa
- Riverside Diner in Ottawa
- Wendy's Fast Food Restaurant in Ottawa
- Sodexo Food Services at Ottawa University in Ottawa
- Burger King Fast Food Restaurant in Ottawa
- Midwest Cabinets (manufacturing) in Ottawa
- Loma Vista Nursery: Midwest Wholesale Nursery Growers
With regards to Day Services that do not pertain to employment, COF has Day Center sites in Ottawa and in Burlington. However, COF does not have a Day Center in Osage City. In Osage City, individuals who choose not to work at the sheltered workshop "setting"or at some other job are provided with a variety of choices of activities/outings and volunteer opportunities. They may also choose to stay home and not participate in day services or employment. This concept is referred to as a wall-less Day Program. Examples of volunteer activities or outings for people who use COF's Day Services within the three counties of Coffey, Osage and Franklin include:
- Prairie Paws Animal Shelter (socializing pets)
- ECKAN (distributing free food to community members)
- Ottawa Main Street Association (watering flowers on street corners)
- Baking & delivering cookies to fire & police departments
- Making & delivering cards to local nursing homes
- Ringing bells at Christmastime for donations to be made to the Salvation Army
- recycling (gathering papers and other various items to be recycled from around the town)
- assisting in community events with cleaning up/handing out food/etc.
- assisting the local library in town
- assisting Catholic Charities with giving children from 1-18 a free lunch Monday-Friday during summer months.
Other fun activities:
- Bi-weekly swimming @ Burlington Rec Center
- Attending local parades, festivals, craft fairs, etc
- Attending movies & other events at Ottawa Memorial Auditorium
- Window shopping at local businesses & large stores like Nebraska Furniture Mart, IKEA, Scheel's, Cabella's, Bass Pro Shop, pet stores, etc
- Movie theaters
- Shopping malls
- Social skills classes
- Ottawa Library
- Fishing, kayaking & picnicking at local lakes
- Yard Sales
- Art classes
- Old train depot in Ottawa
- Gage park lunch and picnic
- Picnic at Emporia zoo
- Rec center for exercise/basketball/swimming
- Community Bingo with quest services in Hartford ks (we provide prizes)
- Attending Movies
- Girls day - nails and nice lunch
- Guys day out - Nice lunch- Shopping
- Chanute Safari Museum
- Ward Meade Park
- Shop and lunch on Saturdays - one staff takes 4 clients to shop and then go to lunch then back to house so the other staff will then take the other 4 to lunch then shop.
- Casino and lunch - take a group to prairie band to play slots or bingo.
- Tour the capital - non guided tour of the capital
- Lunch and bowl (cheesburger fries and a drink, also includes bowling and shoe rental)
- Pumpkin patch
- Attendance at local fairs, holiday activities, and community events
As stated previously CMS' Final/Settings Rule deems Day Centers to be "settings"that segregate and isolate people who are intellectually &/or developmentally disabled (I/DD) from people who are not. It is the intent of CMS' Final/Settings Rule to end this form of segregation of people with I/DD. Some parent / guardians continue to strongly prefer the Day Center model though.
COF will not close its Day Centers as long as there are individuals and parents / guardians who prefer this model and as long as CMS' Final/Settings Rule allows for this option. In the meantime, COF is transitioning gradually from its reliance upon the use of its Day Centers as the primary basis of delivery of day services. The key to this transitioning process is to create greater flexibility with regards to staffing / scheduling / transportation between COF's Residential Services and its Day Services.
COF presently tries to ensure that an array of options from among activities and outings and volunteering are offered to each individual each day. COF is trying to find more and more ways to ensure that the delivery of its day services are not facility-based, but are delivered in such a manner as to ensure that its users are fully engaged and included in their communities. This is "a work in progress”.
Working Healthy/WORK/Independent Living Program
Through its Working Healthy/WORK/Independent Living Program, COF provides services in 20 counties including: Coffey; Osage; Franklin; Lyon; Shawnee; Atchison; Douglas; Johnson; Montgomery; Sedgwick; Sumner; Harvey; Chase; Marion; McPherson; Saline; Butler; Russell; Ellis; and Cheyenne.
The Independent Living Counselors (ILC) travel throughout the state of Kansas, adhere to the State of Kansas WORK program policies and procedures, and assist qualified citizens to choose and direct WORK services, navigate program processes, paperwork and budgets. ILC helps individuals with disabilities increase their income without losing benefits, and is designed to help working people with permanent disabilities take advantage of job career opportunities. Program participants may earn more, save more, achieve their career goals, and still maintain their health coverage. The Working Healthy program serves persons ages 16 through 64 who meet the Social security definition of disability, have verified income from competitive employment, have verified earned income subject to FICA/SECA taxes. Additional points of qualifying information will be discussed at the first meeting with the ILCounselor. The WORK program may help pay for a personal assistant, may help find supported employment, or may help acquire funding for assistive services.
The Director of the Working Healthy/WORK/Independent Living (ILC) Program is Jennifer Moore who may be contacted by calling 316.650.6297 or email firstname.lastname@example.org.
Financial Management Services (FMS)
COF Training Services, Inc. is a licensed provider of Financial Management Services. This is a payroll service for individuals who choose the self-directed services option as opposed to agency-directed services provision. FMS helps parents, guardians and individuals with I/DD who choose to find and coordinate services for themselves. Paryoll deductions, paychecks, and tax information is provided to assist the individual/guardian/parent who selects the self-directed option of service needs.
For additional information about Financial Management Services, contact Carla Bienhoff, CFO (email@example.com), or at 785.242.5035.
COF Training Services, Inc. is a vibrant, active agency which provides an array of individualized services to hundreds of individuals. An agency this large is compelled to review its outcomes in areas of helath and safety, financial analytics, and its response to regulatory oversight. Regular reviews of collected data occur within multiple categories of these three general review areas. Outcomes of this review generate patterns and trends and ensuing recommendations. Staff is given guidelines and assistance or retraining in order to ensure remediation of the quality assurance outcomes. COF’s goal is to continuously improve quality of services so that the individuals who receive services live a healthy, happy, productive and active life
The Director of COF’s Quality Assurance Program is Jennifer Star. He may be contacted at 785.242.5035, or at firstname.lastname@example.org.
Change is inevitable. This is true in every facet of life. It always has been true. And, it always will be true. Change is usually difficult to deal with and to understand. What is unusual with regards to the changes in the field of providing services for people who are intellectually &/or developmentally disabled is the scope and the magnitude of a multitude of changes converging from multiple sources in a short period of time.
At COF, our approach is to deal with the changing reality as it confronts us. We are trying to be proactive, to the extent that it is reasonable to do so. It is difficult because there are no "blueprints”. There are no how-to-manuals. It is important to understand that not changing is not an option. Organizations such as COF are dependent upon Government funding. When your primary funding source which is your primary paying customer tells you that you must change, you have little, if any, choice in the matter.
We understand and respect the frustrations and the concerns of the users of our services and their parents / guardians. We encourage people to contact us with regards to any questions or concerns. Please know, though, that we are excited about our changes. We at COF feel that our responses to changing guidelines and state and federal rules must always be in the individuals’ best interests. Lives are improved; choices are respected; satisfaction with services increases. We’ve been a part of many people’s lives for 50 years, and we are proud of the favorable impact we have had on those who receive our services, and on those who work for the agency. Come see us; we’d surely like to discuss our changes, our future plans, and give you a tour!