Final Rule Changes
Everything must become new with regards to the way that social services are funded & delivered.
Stop and think about it. Human beings have been wandering the face of this earth for thousands and thousands of years. The tremendous amount of effort, of self-exertion from one day to the next is astonishing. Even with historical events as recent as pioneers moving westward in the late 1800s, everybody involved had to exert themselves mightily day-in and day-out. The same held true for the Native Americans the pioneers displaced. The notion that a fairly significant percent of a society needn’t-exert itself to support itself is still a fairly new idea in the grand scheme of human history. Nonetheless, the 50 year experiment of trying to solve societal inequities by redistributing wealth through taxation has seen plenty enough time to understand that it isn’t working. That is because nature, since the earliest of times, has demanded that human beings must exert themselves. If, if in the earliest of times or in the more recent pioneering times, 15% to 20% of the population had been allowed to live without exerting themselves much at all while relying on everybody else to provide them their sustenance, many of the advancements that we take for granted today may well not have come about.
For the past 50 years or more, increasing percentages of the population have lost the drive to exert themselves and have become more and more reliant upon the broad array of government subsidies and government-funded programs. No matter how well intentioned these types of subsidies and programs may have been at the time of their inception, they have proven to be unsustainable through rapidly changing socio-economic circumstances and through the changes of naturally occurring market forces.
Many organizations, such as COF, that were founded to provide important government-funded social services are putting their efforts and resources into fighting to maintain the status quo. This is understandable. Change, though it is constant and inevitable, is difficult. The current system has, to some extent, been functional and viable for the past few decades. Within this context fighting to maintain the status quo may seem to make some sense. No two social services organizations are exactly the same. As such, each organization will choose its own pace and its own path in its response to how it adapts to the rapidly changing socio-economic circumstances and naturally occurring market forces.
At COF we are committed to adapting to those converging socio-economic forces and naturally occurring market forces, which are necessitating changes. We are committed to making changes because we recognize that ignoring the reality that confronts us and trying to maintain an unsustainable status quo will, in the long run, hurt the people who actually do need social services.
Since the beginning of 2014 COF has been going through significant changes in preparation for and in response to what we refer to as the “post-Kancare / post-Final Rule era.” Kancare and CMS’s Final Rule are two prime examples, from among several converging forces, that are having a profound impact upon the way COF and other organizations like it provide services. COF is determined to adapt to these converging forces. In so doing, COF intends to evolve into a new kind of provider of social services.
Please follow us on our website (www.cofts.org) through our evolution into a new kind of provider of social services. Watch for us in the near future on Facebook and Twitter, too. Please check in on us regularly as we go through the process of updating and revising our website. Our goal is ensure that anybody who wants to do so can understand what changes we are making and why we are making these changes.
This section was last updated on 11-16-15.
SOCIAL SERVICES FUNDING in a state of flux
A number of significant socio-economic-political forces are converging that are impacting the way social services are funded and delivered in profound ways. Among these are two key events: 1) Kancare; 2) CMS’s Final Rule. Both of these converging events were implemented in the early part of 2014. Given their newness we are still in the very early stages of their implementation.
This section was last updated on 11-16-15.
The way all types of social services are funded and delivered is changing dramatically. Recent evidence of this fact has been the 02-01-14 inclusion of organizations like COF who provide Medicaid funded services to people with intellectual &/or developmental disabilities (I/DD) into Kancare. Kancare is the managed care model implemented by the State of Kansas in which three very large for-profit insurance companies known as Managed Care Organizations (MCOs) were given sweeping latitude and significant control of the State’s Medicaid dollars and by extension the programs and services that are funded by Medicaid. Instead of continuing to rely upon State bureaucrats to run Medicaid, the State is relying on these three insurance businesses that are accustomed to skillfully operating in the capital market forces so that the natural market forces that have made our country great will come into full play.
It is the State’s contention that Medicaid is no longer sustainable and that something has to be done to control ever-increasing costs. COF agrees with the State’s contention. It is the State’s hypothesis that relying upon Managed Care Organizations (MCOs) instead of state bureaucrats will yield better results and make more efficient use of valuable, but scarce tax resources. Theoretically MCOs are ideally suited to keep the cost of social and medical services contained because they are being provided with a significant profit incentive to control these spiraling Medicaid costs. This is a plausible hypothesis. Time will prove whether or not it is a valid hypothesis.
The implications and ramifications for providers of medical and social services is profound. Minimally, it will force providers of Medicaid-funded services to become far more adept at dealing with and operating in the natural market forces of a capitalist system. The impact of this will almost certainly adversely affect the gross revenue of COF and organizations like it if they fail to adapt. At COF we do not believe hat trying to maintain the status quo is a viable option. At COF we will always choose to deal with reality as it confronts us instead of reality as we would wish it would be. The most important point to understand in this context is that this is among the primary reasons that COF is in the process of making so many changes.
COF recognizes the urgent need for governmental entities such as the State of Kansas to make better and more efficient use of the ever scarcer resources available to them at a time when ever increasing demands are being made on those scarcer tax dollars. COF has every intention of adapting to the circumstances with which we are confronted, no matter what they may be.
This section was last updated on 11-16-15.
Center for Medicaid & Medicare Services (CMS): “Final Rule”
Final Rule Resources:
In March of 2014 the Federal Government’s Center for Medicaid and Medicare Services (CMS) announced what is referred to as its “Final Rule” for the category of Medicaid funding upon which COF relies. This category is known as Home & Community Based Services (HCBS). This Final Rule calls into question every facet of the entire service delivery system for people who have intellectual &/or developmental disabilities that has evolved over the last 40 to 50 years. The fundamental issue of the Final Rule is, in essence, an extrapolated extension of the very important civil rights movement of the mid-1960s. Racially discriminatory practices continued to be prevalent against African-American people in many different ways, even 100 years after the end of the Civil War. Civil rights legislation was necessary. Though the correlation is a bit of a leap, the Federal Government is concerned that the long established system of providing services to people with I/DD has inadvertently been as discriminatory as situations were in the pre-1960s which affected African-American people. The Federal Government plans to assess every type of “setting” where HCBS funds are used to provide services for people with I/DD. They are concerned: 1) that any organization such as COF has too much control over the life of any individual who has I/DD; 2) that the “settings” (i.e. group homes; sheltered workshops; day centers) in which organizations like COF provide services have the effect of isolating or segregating people who have I/DD from people who are not disabled.
With regards to the first point that any organization such as COF has too much control over the life of any individual who has I/DD: the Final Rule is concerned with the gradual evolution of what is sometimes referred to as the provider-centric service system that has been in place for the past 40 to 50 years. The concern is that this long established, deeply entrenched service delivery system for people with I/DD has become too much oriented to the advantage of the rganizations that provide these services instead of to the advantage of individuals who need the services. This first key point particularly impacts Community Developmental Disability Organizations (CDDOs) and Targeted Case Management (TCM) services.
In this context, the Final Rule decrees that any organization that provides services cannot also control or influence: a) the determination of eligibility for services; or b) the amount of funding for services. These two particular functions are among the functions assigned to what are referred to as Community Developmental Disability Organizations (CDDOs). In Kansas, CDDOs are often attached to what are referred to as Community Service Providers (CSPs). COF is a Community Service Provider. CSPs provide the actual services such as residential services; employment services; sheltered workshops; day-center services, etc. The Final Rule views this as a conflict of interest.
Until February of 2015, COF like many other similar organizations throughout Kansas, was both a CDDO and a CSP. COF, of its own initiative, transitioned its CDDO from COF to East Central Kansas Area Agency for Aging (ECKAAA). COF reached out to ECKAAA because it saw ECKAAA as the most logical fit to absorb the CDDO. That is because ECKAAA and all other Area Agencies of Aging perform the two aforementioned functions for people who are aging &/or who have disabilities other than I/DD. In so doing, ECKAAA is now what is known as a single point of entry. This means that in Coffey and Osage and Franklin Counties, a person who is in need of social services can simply go to one place to find out if they are eligible or services and what types of services they are eligible for and where those services can be found. ECKAAA is located at 117 South Main in Ottawa, KS. ECKAAA’s website is www.eckaaa.org. ECKAAA’s phone number is 800-633-5621.This was one of many examples of proactive steps that COF has taken and/or is preparing to take in preparation of this post-Final Rule / post-Kancare era.
In this same context of the notion of so-called provider-centric-organizations having too much control over every aspect of the lives of persons with I/DD, the Final Rule decrees that that any organization that provides services cannot also control the Person Centered Support Plan (PCSP) process. The PCSP is the annual Plan for each individual service recipient. It is meant to be the individual’s plan, not the service provider’s plan. The individual should feel free to choose different categories of service from different service providers if they’d like to do so. For example, a person might want residential services from one provider, but day services from a different provider.
The development of and the updating of and the ongoing monitoring of the PCSPs are the responsibility of the Targeted Case Managers. Many organizations throughout Kansas provide Targeted Case Management (TCM) services among their array of other services. COF, too, provides TCM services among its array of services. This, too, is viewed as a conflict of interest within the context of the Final Rule. For example, from the perspective of the Final Rule, the potential for conflict of interest lies in that if COF provides TCM services, the recipient of those services might feel compelled to use COF’s residential and day services, as well. And, that would give COF too much control over the individual’s life.
As COF has done with its CDDO, COF is taking proactive steps to achieve compliance with regards to TCM services. COF is in the process of preparing and training its targeted case managers to be separated from COF and to be able to operate as independent targeted case managers on their own and/or to be able to align themselves with other free-standing TCM entities that operate independently of COF or any other CSP. COF hopes to have this transition completed before 06-30-16. The goal is that people who have come to trust in and rely upon COF’s TCM services over the years will be free to follow COF’s former case managers after the have separated from COF if they choose to do so.
Preparing for this separation has been a very complex process and the transition process itself will be equally complex when the final steps are taken to facilitate the separation. As with the separation of its CDDO, the separation of its TCM is being done by COF because we feel that this is xplicitly required by CMS’ Final Rule. Furthermore, in reviewing Kansas laws pertaining to the TCMs and the CDDOs written years ago, the need to have protections for the potential conflicts of having CDDOs and TCMs and CSPs operating together under the auspices of one organization was clearly recognized.
With regards to the second key point that the “settings” (i.e. group homes; sheltered workshops; day centers) in which organizations like COF provide services have the effect of isolating or segregating people who have I/DD from people who are not disabled: the established network of sheltered workshops and day centers that have existed across the Country for the past 40 to 50 years is in jeopardy. By definition, these types of “settings” have the effect of isolating people with I/DD from non-disabled people. These types of “settings” exist for no other purpose than to provide services to a group of people who have a particular type of disability. The only people who come to and make use of these types of “settings” are people with I/DD and staff who are paid to provide services to them.
The Federal Government’s new interpretations via the Final Rule deems this as a form of segregation in that these “settings” have the effect of isolating persons with disabilities from persons who are not disabled. The Final Rule decrees that in the course of any day of any person who has a disability, that person has every right to interact with as many non-disabled people in the course of his or her day as does any non-disabled person in the course of their day.
Additionally, the Final Rule puts very special emphasis on the formal definitions of competitive employment and integrated employment.
- Competitive employment means work (i) in the competitive labor market that is performed on a full-time or part-time basis in an integrated setting; and (ii) for which a person is compensated at or above the minimum wage, but not less than the customary wage and level of benefits paid by the employer for the same or similar work performed by persons who are not disabled
- Integrated setting means, with respect to an employment outcome, a setting typically found in the community in which applicants or eligible persons, to the same extent that non-disabled individuals in comparable positions interact with other persons.
The Final Rule very especially emphasizes that every person with I/DD should be given opportunities for competitive and integrated employment. COF wholly embraces the importance of and value of meaningful employment opportunities for people with I/DD and for people who are otherwise chronically underemployed and who are consequently overly reliant upon various forms of government subsidies for their sustenance.
IEE and TWL Resources
- Integrated Employment Enterprises
- Tax Weight Loss(tm)
- Customized Employment Services
- Employment Network Certification
- Vocational Rehabilitation Vendor Certification
- Rehabilitation Services
- State VR Department
For these same reasons, group homes that are owned, operated or controlled by organizations like COF are subjected to what CMS’ Final Rule refers to as “heightened scrutiny.” The Final Rule presumes that the lives of people with I/DD are too much controlled by organizations like COF and that residents living in homes owned, operated or controlled by organizations such as COF might be denied sufficient opportunities to be integrated and included in the communities in which they reside. So, as with sheltered workshop “settings” & day service “settings,” group home “settings” will also be assessed to ensure that those group homes do not have the effect of isolating people who are disabled from people who are not disabled and to ensure that residents of these types of “settings” are afforded equal opportunities to be integrated into and included in the communities in which they reside.
Additionally, whether or not group home “settings” have the effect of being operated as institutionalized settings will be assessed. This is because in the not too distant past people with I/DD were “warehoused” in large congregate living institutional settings that we generally segregated from the rest of society. From the 19802 onward, group homes gradually became prevalent as the alternative to these large, segregated institutional settings. Unfortunately, some group homes became mini-institutions and were operated in much the same restrictive manner as the large institutions had been operated. Institutional practices were carried over into the smaller group home settings even though these homes were otherwise integrated into typical middle class neighborhoods.
CMS’ Final Rule, for example, requires that people who reside in group homes that are owned, operated or controlled by a CSP not be subjected to regimented schedules suited to the CSP’s staffing needs. All eight residents of a group home, for example, should not be required to ride a bus, together and at the same time, that is also owned and operated by the CSP, in order to report to a day services center that is owned and operated by that same CSP. The Final Rule contends that individual residents should have individual choices if or when they go to a day center, or if they go at all to a day center, or if they go to another day center operated by different CSP. Similarly, access to food and to meals that are not regimentally scheduled will be required along with a host of other changes that will cause CSPs that own, operate, and control group homes to soon change the way that they operate the group homes.
This section was last pudated on 11-16-15.
The problem defined
There is a great need to change this inverted social services delivery system that unintentionally supports co-dependency between the provider of social services and the recipient of social services. Current funding rate methodologies essentially foster continued dependency upon government resources.
- The problem: Organizations that provide social services and the people who receive those services are inadvertently dis-incentivized. The motivation for users of these government funded social services to exert themselves in order to sustain themselves is removed. Self-exertion for survival and sustenance is something that had been innately wired into the human psyche from the very beginning of time. Similarly, those organizations that provide these important social services inadvertently foster the reliance of the users of their services upon that social services organization because that is how governments have designed the funding upon which they must rely. This, in turn, can have the unintended effect of those very social services organizations not having to exert themselves in the same ways that businesses that have to survive within the natural market forces do.
- The solution: Reward providers of social services proportionally to the amount of decrease in tax-funded-dependency of service recipients which is created as a direct result of the services provided. Both the provider of social services and the recipient of social services would then be incentivized to exert themselves in a more purposeful manner. The organizations providing social services would be incentivized in ways that would stimulate the innovation and creativity that are the hallmarks of the capital market system. That incentivation would, in turn, cause the recipients of those services to exert themselves to decrease their reliance upon the various forms of government subsidies.
The multitude of not-for-profit organizations that deliver important and valuable social services of all types are being confronted with the same reality that all for-profit entities have long since been confronted with as a routine matter of course. Change is inevitable. Adapting to the reality that confronts us is a necessity in this capital market-driven system. No enterprise of any kind, including not-for-profit deliverers of social services such as COF, is immune from natural market forces. COF and other organizations similar to it can no longer afford to passively stand by on the sidelines in these difficult socio-economic circumstances and rely on the primary source of revenue, the government, to solve their problems.
Since the mid-1960s when Medicaid came into being, converging market forces have changed the socio-economic landscape of our great Country. Medicaid is the Federal program that was implemented to help people with little or no income to access medical and social services. Medicaid is the primary source of funding for COF. As with most so-called “big-government programs,” it has grown significantly in its brief history of approximately 50 years to the point where as many as 15% to 20% of the population have some degree of reliance upon Medicaid and/or other types of government subsidies. Common sense should tell most people that allowing that much of the population to be “recipients” of and reliant upon government-funded services is problematic. This problem has been compounded by two issues: the mass exodus of jobs to other countries, and automation that has also taken jobs. People who have jobs pay taxes. Taxes are the sole source of revenue for government-funded services. Put simply, Medicaid is not sustainable in its present form due to these naturally occurring market forces.
The single best remedy to enhance the sustainability of a social service safety net is jobs. People who do not have jobs do not pay taxes. People in foreign countries who now hold jobs that were previously held by American citizens are not paying taxes in the United States. Many, though not all, of those jobs that have been outsourced to other countries could just as easily be re-outsourced to the United States, thus providing income-earning opportunities to people who have I/DD and/or other types of actual disabling conditions that validate the need for some type of government assistance. Many, many people who have I/DD want to work and are capable of earning enough income to decrease, in varying degrees, their reliance upon government assistance.
People who have I/DD are a unique subcategory of Medicaid recipients. If individuals from this unique subcategory who do have a very real disability can decrease their reliance upon government assistance, it stands to reason that most other subcategories of Medicaid recipients could do the same. However, insufficient volume of income-earning opportunities is the too often overlooked corollary of over-reliance upon Medicaid and other similar types of programs. Capitalism, by its nature, will pursue the most cost-effective labor source without regard to the national boundaries within which all entities that are empowered to levy taxes must operate. Without substantive tax-incentives to do so, there is no reason, in a capitalist system, to keep paying ever increasing labor costs when more cost-effective labor is in ample supply beyond national boundaries.
The problem and its solution are essentially simple. However, complications set in because State and Federal government action is needed to bring about the changes that are needed to solve the problem which coincidentally was, with good intentions, created by the government in the first place. Further compounding the difficulties of proceeding with proposed solutions is the resistance that always comes from those entities that have a vested interest in maintaining the status quo.
That state of Kansas’ attempt to solve the problem is Kancare. The Kancare experiment at its essential core is an attempt to bring government funded social and medical services into natural capital market forces by removing control of such services to the greatest extent possible from government control and rendering that control to Managed Care Organizations (MCOs) which are highly skilled at operating in the capital market forces.
At the Federal level, CMS’ Final Rule is an attempt to solve the problem by gradually unraveling a provider-centric-system that, over time, has gradually ballooned in size and has inadvertently taken precedent in government funding over the very people for whom it was it was intended to provide services. CMS’ Rule and the state of Kansas’ Kancare are two distinctly separate governmental attempts to solve a problem. They are separate, powerful converging forces that coincidentally are occurring simultaneously. COF is fully committed to doing its best to adapt to both of these powerful converging forces.
Nonetheless, COF is committed to proceeding with the implementation of its TAX-WEIGHT-LO$$ ™ process because of the belief that it strikes the hardest and the closest to the actual problem at hand. And, it is well suited to accentuate both of the aforesaid approaches (CMS’ Final Rule and Kancare) of the state and federal governments.
To this end, COF has developed the TAX-WEIGHT-LO$$™ process. We believe that COF’s TAX-WEIGHT-LO$$™ process has the potential to change the paradigm of over-reliance upon Medicaid and other types of so-called “big government programs” which have become unsustainable over time due to naturally occurring converging market forces. Instead of looking to and waiting for the government to solve our problems, at COF we are, to the extent that we are able to do so, trying to take matters into our own hands. In other words, at COF which stands for Coffey & Osage & Franklin counties, we are trying to Control Our Future.
The TAX-WEIGHT-LOSS™ concept is simple. Every person who relies on government subsidies of any type bears a “tax-weight.” The amount of each person’s “tax-weight” varies depending on a number of factors. Tax weight, though, is generally easily calculated by adding the amounts of the various types of government subsidies upon which an individual relies. For example, most people who receive services from COF receive, among other things: Social Security Disability; Supplemental Security Income; food stamps; subsidized housing; medical benefits. We add those amounts and that creates their “tax-weight.” Separately, we add the cost of the services that COF provides, too. That’s how we determine each person’s tax-weight.
For example, John Doe receives per year: SSDI $12,000 + SSI $0 + food stamps $720 + housing subsidy $6,000 + other (i.e. medical) $1,000 = tax-weight of $19,720 per year. Then we add the costs of COF’s services because part of our tax-weight-loss™ concept is that organizations like COF should look for ways to decrease their tax-weight loss, too. If, for example, COF’s service component for john Doe costs $50,000, John Doe’s tax-weight would equal $69,720. There is generally an assumed correlation between a person’s tax-weight and the person’s need for government subsidies: the higher the need, the higher the tax-weight.
There is really only one way for a person who is reliant upon various government subsidies to lose some or all of his tax-weight. This can only be done through earning more income. To lose tax-weight, a person has to replace the unearned income they receive in various forms via government subsidies with earned income via working at paying jobs.
However, the natural market forces of a capitalist system aren’t designed to absorb lesser-productive workers who have a disability of some type. The corollary of the exodus of jobs to escape the gravitational powers of state-imposed and federal-imposed tax-costs exacerbates the problem. In a capitalist system, employers need to have something besides altruism to motivate them to absorb lesser productive workers. Tax incentives of a very substantive nature is the obvious thing to do. Tax-incentives as close to dollar-for-dollar as possible with as little bureaucratic red-tape as possible are needed. If, instead of employers routing their tax-dollars to Federal and State and County governments so that government bureaucrats can in turn redistribute those tax-dollars in the form of subsides that are free to recipients, employers could steer those same dollars towards the employment of people who rely on government subsidies, it would gradually change the cyclical paradigm of ever increasing taxation and ever increasing reliance upon government subsidies. It is a simple bipartisan concept. The tax incentive is not a simply break for the rich in the hopes that maybe their tax break will trickle down. Nor is it the simple redistribution of wealth through taxation whereby the recipients need to do little, if anything, to receive the redistributed wealth. It strikes at the too oft overlooked corollary between higher and higher taxes and regulations on employers and the mass exodus of jobs to find less expensive labor costs. It’s really that simple.
Not all people who are reliant upon Medicaid and other government funded subsidies are created equal. Most people with I/DD are not among the primary contributors of the problems which are often associated with an overly expensive social ervices safety net that fosters dependency upon the government; a safety net which in turn, burdens well intentioned, ard-working, tax paying citizens and corporations with added costs that could be better spent to naturally stimulate economic growth instead of continuing to inefficiently waste more and more tax dollars.
Persons with intellectual &/or developmental disabilities (I/DD) are particularly unique in that they are born with a horrific blow of fate that impedes their ability to fully compete in the work force. However, all people who rely upon government resources, including but not limited to Medicaid, share a common denominator: each of them bears a measurable “tax-weight” that is borne by productive tax-paying citizens. Most tax-payers do not begrudge those who legitimately need and use the tax-funded social services safety net if these individuals are exerting themselves by making a legitimate, concerted effort to decrease their reliance upon other citizens’ tax dollars.
Persons with I/DD are not all created equal either. For example, IQs of persons with intellectual disabilities ranges from zero to 70. The average IQ for so-called normal intelligence is 100. A person with an IQ of 50 has a much greater capacity to decrease his or her reliance upon government subsidies than a person whose IQ is 10. Most people with I/DD are not able to wholly eliminate their tax-weight. Their disabilities manifest in different ways and to varying degrees. While their capacity to decrease their tax-weight will vary, every single dollar of decreased reliance upon the government helps everybody.
Generally, the individuals with I/DD who fall within a unique sub-category of the over 350,000 Kansans who receive some type of Medicaid funding:
- are not lazy;
- are not looking for an easy way out;
- do not expect the government to simply “take care of them;”
- are not ingesting or abusing drugs and alcohol;
- are not exercising their reproductive capacities without regard to how they will support the children that they bring into the world.
are not deliberately bilking or manipulating the welfare system;
The desired outcome of COF’s tax-weight-loss™ initiative which was implemented in earnest as of April 1st, 2015 is twofold:
- to demonstrate that if all people in general who are reliant on various forms of government subsidies for their sustenance and, in particular, the unique subcategory of people who have inborn intellectual and/or developmental disabilities, can significantly decrease their reliance upon tax-funded sources (i.e. decrease their “tax-weight”), the costs of subsidies will decrease while tax revenues will increase through the employment of previously underemployed people: >>>>>> !!! *** ESSENTIAL to regularly provide updated t-w-l data and individual stories of people who have benefitted from t-w-l !!! ***
- to demonstrate social services organizations such as COF can indeed adapt to converging events that have been naturally occurring in capital market forces. These events have contributed to the lack of sustainability of Medicaid and other similar types of funding sources upon which social service organizations primarily rely.
In the grand scheme of things, COF is nothing more than a tiny, insignificant, provider of social services. We remain humble, but we are committed to making these changes in our small piece of the world. We believe that our TAX-WEIGHT-LO$$ process is the first step in what could ultimately lead to the paradigm shift that is needed in social services. With or without tax incentives to decrease individuals’ tax-weight, COF remains committed to finding competitive and integrated employment opportunities for the people to whom it renders supports and services, thus helping them to decrease their reliance on government subsidies in varying degrees in accordance with their abilities to do so.
COF: “where the tax-weight-loss(tm) revolution begins”
COF cannot stop the remarkable array of changes that are confronting the social services delivery system. However, at COF we can and will endeavor to control our future by diligently adapting to the ever changing reality with which we are confronted. Kancare and CMS’ Final Rule are two of several significant changes confronting COF. In addition to adapting to these important changes, we hope, in our small way, to facilitate change through our tax weight-loss proposal which we are trying to get enacted legislatively. Please follow our updates on this website (& facebook & twitter)
Change is inevitable.
We at COF are committed to embracing the exciting challenges that positive changes require!