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Governor’s FY ’21 budget encourages more privatization of DDS programs
Continuing an ongoing pattern, Governor Baker’s proposed state budget for the coming fiscal year is far more generous to corporate provider-based programs overseen by the Department of Developmental Services (DDS) than to DDS state-run programs.
Last week, Baker unveiled his $44.6 billion state budget plan, which would provide $2.15 billion in funding to DDS-related line items.
We’ve been concerned for years that the Legislature and a succession of administrations have underfunded DDS state-run budgetary line items — a trend that only encourages further unchecked privatization of those services.
Some key details of our analysis of Baker’s proposed budget for DDS are below:
State-run program line items
A key state-run program to start with is the DDS network of state-operated group homes.
Under Governor Baker’s Fiscal 2021 budget, the state-operated group home line item would be increased by $6.4 million over the current year, which is only just above the rate of inflation. The increase would bring the state-operated group home line item to $237.8 million in Fiscal 2021.
State-run group homes provide a critical backstop of care due to their low staff turnover and relatively low per-client abuse rate. Yet, data also show the number of residents in state-operated group homes has been dropping as the administration and Legislature have targeted more funding to the much larger network of corporate provider-operated group homes. DDS also does not routinely offer state-run group homes as a residential option to individuals.
Meanwhile, the state-run developmental centers line item would be cut in the coming year, continuing the pattern over the past decade. The developmental centers also provide an important backstop of care for some of the most profoundly developmentally disabled residents of Massachusetts.
Under Baker’s Fiscal 2021 budget, the cut in the developmental centers line item would be $560,000, which would amount to an inflation-adjusted cut of almost 3%. That would drop the line item to $104.3 million in Fiscal 2021.
The DDS administration line item, which includes critically needed DDS service coordinators, would actually get a modest increase under the governor’s budget. That line item would be raised by $5.3 million over current-year funding, to $80.2 million. That would amount to an increase of 4.6% when adjusted for inflation.
But among those three state-run program line items (state-operated group homes, developmental centers, and DDS administration), the average overall increase from the current year would be less than 1% when adjusted for inflation.
Moreover, since Fiscal 2012, those three line items will have been cut by an average of about 1.3% in inflation-adjusted terms. The developmental center line item alone will have been cut by $73.5 million, or more than 40%, since Fiscal 2012.
The two charts just below illustrate the trend lines since Fiscal 2012 for key state and provider-run programs in the DDS system.
The corporate provider line items
In contrast to the state-run programs, three key provider-based line items — corporate provider group homes, provider-run day programs, and transportation services — would be increased on average by 4% from the current fiscal year, under Baker’s budget. Since Fiscal 2012, those three line items will have been increased, on average, by almost 90%.
Baker’s Fiscal 2021 budget proposes increasing the provider group home line item by $9.5 million, to $1.287 billion. That is a relatively small increase, given the size of the line item, and actually would amount to a cut of 1.7% when adjusted for inflation. However, funding for that line item has risen dramatically since Fiscal 2012. If Baker’s budget proposal is enacted, funding for provider group homes will have increased by $407 million, or 46%, over the past 10-year period.
Meanwhile, other provider-based line items would be increased by significant amounts next year, under Baker’s budget plan.
Under the governor’s budget, the provider-run transportation line item would be increased by $3.8 million, to $33.3 million over the current year, which is more than a 10% increase when adjusted for inflation.The provider-run day program line item would be increased by $14.4 million, to $253.9 million. That would amount to a 3.5% increase over the current year.
Since Fiscal 2012, the provider-run day program line item will have been increased by 75%, and the transportation line item by 146%, if the governor’s Fiscal 2021 budget is enacted.
Chart shows some clear trends
These funding trends can be seen in the two charts above. For instance, the first chart shows the opposite directions in which funding has gone regarding provider group homes and state-run developmental centers. We’ve long expressed concerns about the closures of four of the state’s six remaining centers between 2008 and 2014.
At nearly $1.3 billion, the provider group home line item now dwarfs every other DDS line item in the budget.
Similar trends can be seen in the second chart for other provider versus state-run line items. For instance, funding for state-operated group homes peaked in Fiscal 2016 at $238.3 million, in Fiscal 2021 dollars. Baker’s proposed funding for Fiscal 2021 for state-operated homes is still less than what was appropriated by the Legislature in Fiscal 2016.
Meanwhile, funding for provider-run day programs caught up with the funding level for the state-operated group homes in Fiscal 2019 and surpassed the latter line item in the current year. Baker’s proposed Fiscal 2021 budget would continue that upward trend for the day program line item.
While the combined state-run DDS administration and service coordinator line item would get a 4.6% increase next year under Baker’s plan, the funding trend for that line item has been essentially flat after peaking in Fiscal 2016 at $77.4 million.
In contrast, the provider-run transportation line item, while dipping slightly in Fiscal 2017, has continued to rise since then.
Other DDS line items
Overall, the DDS budget would be increased by just under 0.2% under the governor’s Fiscal 2021 budget proposal. It reflects a mixed level of increases and cuts for a number of other line items that don’t fall as clearly into the state-run or provider categories, but are a combination of the two.
The Turning 22 line item would get a very small increase of under $2,000 under the governor’s budget. That would amount to an inflation-adjusted cut of 2.4%. Interestingly, Baker’s budget message touted that he has been “fully funding” Turning 22 for the past four years. It’s not clear on how that squares with the actual budget proposal.
Respite and Family Supports would be increased under the governor’s budget by $7.8 million, or 8.4%.
The Adult Autism line item would be increased by $7.8 million, or 22.5%.
Disabled Persons Protection Commission (DPPC)
The DPPC line item is not under the DDS budget, but the DPPC performs a key role as the state’s only independent agency that investigates abuse and neglect of disabled adults. Yet this agency is chronically underfunded.
Baker’s Fiscal 2021 budget would increase the DPPC line item by a very modest $129,000, which would amount to an inflation-adjusted increase of well under 1%. Since Fiscal 2012, DPPC’s budget will have been increased by 94%; but the agency is still unable to afford more than a handful of staff to investigate abuse complaints, and must hand most of those investigations off to DDS and other line agencies to investigate.
We hope, in upcoming meetings with key legislators, to impress upon them the importance of a more equitable funding allocation between state-run and provider-run programs.
If current trends continue, state-run services will continue to wither away through declining funding and attrition, and we will end up with a fully privatized system of DDS-funded services. We are concerned that that is a prescription for a race to the bottom in care.
A newspaper’s coverage of abuse and the enactment of Nicky’s Law are steps in the right direction
One newspaper in Massachusetts has been shining a spotlight lately on the problem of abuse and neglect of persons with developmental disabilities in the state.
Meanwhile, the state Legislature took a strong step last week in barring abusive caretakers from working for providers in the system.
Yet these two positive developments also highlight the fact that the media in Massachusetts in general and the Legislature as a whole have to do more than they have been in recognizing ongoing problems in the care of persons served by the Department of Developmental Services (DDS).
As we have long maintained, these problems have gotten steadily worse as functions and services for the developmentally disabled have been steadily privatized over the years without sufficient oversight of the corporate provider-based system.
One newspaper’s systematic coverage and one important legislative victory appear to be the exceptions to the rule, which has generally been one of benign neglect on the part of the media and Legislature.
The media exception has been The Springfield Republican, which published an in-depth report on January 10 about a DDS corporate provider, Guidewire, Inc. The newspaper revealed, among other disturbing facts, that at a Springfield group home operated by Guidewire, staff encouraged residents to fight each other and awarded prizes including money, cigarettes, marijuana and alcohol.
Perhaps not coincidentally, the article ran just a few days before the Massachusetts House unanimously approved a bill that would create a registry of caregivers found to have committed abuse or neglect. Such persons would be banned from future employment in DDS-funded facilities. The bill known as “Nicky’s Law,” which was passed by the Senate in October, is expected to be signed into law by Governor Baker within the next 10 days.
A few days before the Springfield Republican article ran, the same newspaper published a follow-up to COFAR’s blogsite report about the termination of a DDS contract with another DDS provider, the Center for Human Development, to operate two group homes in which care was found to be substandard. In that case, COFAR had first reported allegations of poor care raised by the foster mother of a resident of one of the group homes.
Last year, the Republican followed up on COFAR’s initial reporting on CHD, and ran a comprehensive article about the failure of DDS’s licensure inspection process to identify ongoing problems in the two CHD group homes.
Both the reporting by the Republican and in COFAR’s blog posts helped to spur an internal investigation of CHD by DDS. Last fall, the DDS Bureau of Public Integrity cited potential “systemic issues” across CHD group homes.
Guidewire details underscore the need for Nicky’s Law
According to the Republican. eight employees of Guidewire were fired after the “fight club” details were brought to the attention of DDS in 2011. But the employees were given the right to return to work at other DDS-funded facilities in 2018. And while Guidewire was subject to a corrective action plan and staff were retrained, no criminal charges were filed in the case.
To that extent, the Guidewire case underscores the need for Nicky’s Law, which would potentially have prevented DDS from continuing to employ those caregivers.
Persons applying for caregiver positions in the DDS system currently must undergo criminal background checks, which disclose previous convictions for abuse and other crimes in Massachusetts and other states. However, even when abuse against persons with developmental disabilities is substantiated by agencies such as the Disabled Persons Protection Commission (DPPC), it does not usually result in criminal charges. As a result, those findings of substantiated abuse are not made known to providers or other agencies seeking to hire caregivers. That’s why an abuse registry is needed in Massachusetts.
The Springfield newspaper cited COFAR’s own findings last September in which we identified Guidewire as one of the service organizations in the state with the most abuse complaints filed, substantiated and referred for criminal prosecution.
More recently, we analyzed DPPC data on a per-client basis to control for size of each provider, and found that between Fiscal 2010 and 2019, Guidewire was third highest out of 75 providers surveyed in the number of substantiated abuse cases per client. Guidewire was third as well in complaints referred per client for criminal investigation.
But abuse and poor care are problems that go far beyond one provider. COFAR analyzed the outcomes of more than 14,000 abuse complaints in the Fiscal 2010-2019 period.
Rest of the media needs to examine these issues
The Springfield Republican’s reporting shows the good things that can happen when the media shines a light on issues and activities that are causing harm. But it usually takes a commitment and cooperation among several media outlets to place these matters on the agenda of politicians and policymakers in order to bring about real change.
Unfortunately, with the exception of the Republican, the mainstream media in this state has shown little interest in systematically reporting on the serious problems that afflict the care of persons with developmental disabilities in the DDS system.
Major investigations have been undertaken of abuse of the developmentally disabled in group homes by newspapers in other states in recent years. Those reports include multi-part exposes starting in 2011 by The New York Times, in 2013 by The Hartford Courant, and in 2016 by The Chicago Tribune.
The mainstream media in Massachusetts has yet to to pay more than passing attention to the DDS system. We have also not had any success in getting a response from The Boston Globe to our concerns about currently proposed legislation that would make the state’s process of investigating abuse of the developmentally disabled far less transparent.
Children and Families Committee has yet to demonstrate a serious concern about the issues
We are also trying to persuade the state attorney general and the Legislature’s Children, Families, and Persons with Disabilities Committee to begin seriously looking at these issues. While we applaud the role played by the Children and Families Committee in getting Nicky’s Law enacted, the committee has yet to demonstrate a sustained commitment to examining and addressing the problems within the DDS system.
In 2018, the Children and Families committee held two informational hearings on abuse and neglect in the DDS system. But members of the general public were not permitted to present verbal testimony at either hearing, and the committee never followed up on those hearings with a report. It’s not clear what, if any, the purpose of those hearings was.
In the final analysis, media attention and the attention of legislators and policymakers are linked. Legislators, in particular, are not likely to act to address society’s problems if the media isn’t focusing on those problems. It seems we’ve entered an age in which the media’s attention is more fractured than ever before.
The enactment of Nicky’s Law is one example of a piece of legislation that the media did get behind. Yet, the enactment of that law is just a first step in what needs to be a comprehensive reform of the system.
Every now and then, a media outlet like The Springfield Republican gives us hope that there still are journalists out there who will go further than reporting on one bill and will examine the issues underlying the legislation.
Once the media focus is there, we think legislators and policymakers will act more systematically on issues of concern to those people they are supposed to protect — the most vulnerable people in society.
A disability abuse investigation agency bill has two words in it that could authorize the agency to seal all its investigative records
We are expressing concern over two words in a bill concerning the state Disabled Persons Protection Commission (DPPC) that could authorize the agency to seal all of its investigative records regarding abuse of persons with disabilities in Massachusetts.
In an email we sent this week to state Representative Aaron Michlewitz, chair of the House Ways and Means Committee, and other key lawmakers, we pointed out the potential problem inherent in the language of Section 17 of what is now H.4231. The bill section would change the DPPC’s enabling statute to state that “all confidential information” in the DPPC’s possession shall not be a public record.
The DPPC is the state’s only independent agency charged with investigating allegations of abuse and neglect of adults under the age of 60 with developmental and other disabilities. The DPPC has jurisdiction over a wide range of investigations done by its own staff and the staff of a variety of other agencies.
Those are the two problematic words in Section 17 of H.4231: “confidential information.”
We have no objection to a separate portion of the same sentence in the section stating that “all personally identifying information” shall not be public. But the “confidential information” phrase is poorly defined and so overly broad that we think it would give DPPC the discretion to label virtually anything it wants as confidential and therefore secret.
We are asking people to call the House Ways and Means Committee at (617) 722-2990, and simply urge them to take the words “confidential information” out of Section 17 of H.4231.
As we understand it, Section 17 was recently reworded by the Children, Families, and Persons with Disabilities Committee to respond to concerns we raised last year that the section would potentially make most of the records of the DPPC non-public. The reworded language would be fine with us if the House Ways and Means Committee would simply take out those two words.
Here’s our reasoning for this, in a nutshell:
Right now, DPPC’s enabling statute (M.G.L. Chapter 19C) simply says that the Commission should “…disclose as little personally identifiable information as possible.” There is no reference in the enabling statute to “confidential information.” The enabling statute, moreover, invites the presumption that the agency’s records overall are public. Nowhere does the enabling statute state that the DPPC’s records, in general, are not public.
The DPPC’s regulations, however, do refer to “confidential information,” and define it as including “personal data” and “any and all notes, papers, documents or other investigative materials, including but not limited to interview summaries, collected or compiled by personnel duly authorized by the Commission during the course of an investigation.”
This DPPC regulation (118 CMR 9.03) also specifically states that: “The records of the Commission shall not be considered ‘public records'” (my emphasis).
So, there are at least two inconsistencies between the DPPC’s regulations and its enabling statute, and it would seem that what DPPC is trying to do is make its enabling statute consistent with its regulations in stating at anything that it considers “confidential” is not a public record. As we’ve said before, though, this is a bad direction for DPPC to go. It should change its regulations to be consistent with its enabling statute, not the other way around.
It would seem that what DPPC wants to do is to be able to say that all investigative materials of any kind are potentially confidential and therefore not public records. That is bad news for the public’s right to know.
We actually don’t think Section 17, as a whole, of H.4231 is necessary for reasons I’ll get to below. But, as noted, what we are recommending is that, at the very least, the House Ways and Means Committee remove the words “confidential information” from the section.
Our argument with respect to Section 17 and to DPPC’s secrecy regarding its records in general has always been about the public’s right to know. Complaint-specific information can be a key window into the nature of problems of abuse and neglect in the care of persons with disabilities and in how the state deals with those problems.
Section 17 isn’t necessary
As noted, we don’t think Section 17, as a whole, of H.4231 is needed. The DPPC’s enabling statute, as currently written, gives DPPC the discretion to block “personally identifiable” information, and so does the state’s Public Records Law itself.
The Public Records Law (M.G.L. Chapter 4, Section 7, Clause 26) specifically exempts from disclosure “data relating to a specifically named individual, the disclosure of which may constitute an unwarranted invasion of personal privacy.” The Public Records Law further exempts “investigatory materials…the disclosure of which materials would probably so prejudice the possibility of effective law enforcement that such disclosure would not be in the public interest.”
The Public Records Law presumes state agency records are public
As the Secretary of the Commonwealth has opined, the state’s Public Records Law presumes all state agencies’ records are public unless a specific exemption in the Public Records Law applies to those records. The first exemption listed in the Public Records Law, known as “exemption (a),” is the enactment of another statute that exempts records of any kind from disclosure.
If Section 17 of H.4231 is enacted as currently drafted, it would change the DPPC’s enabling statute to specifically prevent the disclosure of any material deemed “confidential.” As a result, if any member of the public were to ask for any information that DPPC considered confidential, DPPC could invoke Exemption (a) of the Public Records Law without having to demonstrate that the information was personally identifiable or that it would prejudice effective law enforcement.
DPPC could simply refer to the vague “confidential information” phrase in its enabling statute, and the agency could forever seal those records from public disclosure. The state Public Records Supervisor’s hands would be tied in those cases if anyone were to file an appeal of the denial of the records by DPPC.
So, once again, we believe the potential problem we have described can be avoided by the simple removal of the words “confidential information” from Section 17 of H.4231. We hope the House Ways and Means Committee does that, or, better yet, removes Section 17 altogether.
DDS terminates contract with provider to operate two problematic group homes
The state Department of Developmental Services (DDS) has terminated a contract with a corporate provider to run two problematic group homes in East Longmeadow for persons with developmental disabilities.
The contract termination with the Springfield-based Center for Human Development (CHD) was confirmed to COFAR on Monday (January 6) by the provider.
The DDS action, which appears to be relatively unusual for the department, came after Mary Phaneuf, the foster mother of a resident of one of the group homes, alleged poor care in her son’s residence. She said she was told by DDS that due to the contract termination, her son, Timothy Cheeks, and other residents in his home will have to move this month to another residence operated by another provider in Longmeadow.
Starting in 2018, Phaneuf alleged a lack of proper medical care for Tim, including no documented visits to a primary care physician or dentist for seven years. She also said there were no documented visits to a cardiologist for six years despite Tim’s having been born with a congenital heart defect.
Phaneuf’s allegations led to DDS investigations last year, which found “potential systemic issues” throughout CHD’s residences, according to a DDS summary document obtained by COFAR. Her allegations also led to the adoption of new management policies by CHD.
Tim Cheeks with his foster sister Nicole Phaneuf Sweeney
COFAR’s blog posts in July and in August concerning Phaneuf’s allegations, and coverage by The Springfield Republican, led to the DDS investigation of the provider.
No comment yet from DDS
As of today (January 7), DDS had not responded to an email from COFAR on December 18 seeking comment on the status of CHD’s contract to operate the residences or the results of its investigations. In the same email, which was addressed to DDS Commissioner Jane Ryder, COFAR also requested completed reports and action plans in the case, under the state’s Public Records Law.
As required by the Public Records Law, DDS did respond on January 3 to the public records request in COFAR’s email, saying that the department expected to produce the requested documents by January 10.
COFAR also sought comment on December 18 from CHD. In an email in response on January 3, Ben Craft, vice president of community engagement for CHD, stated the following:
CHD is fully engaged in comprehensive changes in policy and operations to return and sustain the quality of our DDS services to the high standards that we have upheld across our organization for nearly fifty years. Substantial implementation of these improvements has already occurred, and that work continues.
CHD will continue to work hand in hand with DDS to help ensure that our system of care for people with disabilities is meeting their needs while at the same time empowering them to live with the highest degree of independence possible. CHD will actively participate in continuing dialogue with DDS and other state partners about opportunities to improve public-private partnership in service delivery and policy.
Regarding the continuing operation of the two residences, Craft said in the email that CHD, which owns one of the two homes in question, had entered into a lease arrangement for that residence with the new provider, Mental Health Association, Inc. (MHA), “to ensure a smooth transition as MHA prepares homes to accept individuals now being served by MHA.” MHA is also based in Springfield.
Phaneuf said she was told the lease is temporary and that is why her son and the other residents of his home will have to move later this month to an MHA-run group home in Longmeadow. Phaneuf said she was told that two CHD employees from the original house would transfer to her son’s new residence, but would be employed by MHA.
DDS found “potential systemic issues” with CHD
In December, Phaneuf forwarded to COFAR an untitled and undated summary document from DDS about the investigations by its licensure office and its financial investigation unit of CHD. The DDS summary document appears to contradict previous statements by CHD that the problems Phaneuf raised were largely the result of mismanagement by a single staff member – a former house manger of Tim’s group home.
The summary of the review by the DDS Bureau of Program Integrity, which appears to date from September, specifically stated that:
While some of the issues (raised by Phaneuf) can be attributed to the former house manager, the lack of oversight and control procedures are indicators of potential systemic issues across CHD homes.
The DDS summary document also cited a “significant volume of missing and erroneous records provided by CHD” for DDS’s review, and recommended that a full audit of client funds records for all of CHD’s DDS-funded group homes be done by an external agency or firm. The document also said that the “complete independent audit” should cover a two-year period.
In addition, the DDS document stated that while there was no direct evidence of fraud by CHD, the agency must provide complete restitution of the personal funds “for which they cannot provide validation of appropriate expenditure.”
The DDS document also cited a failure by the former house manager to maintain financial transaction records, and a lack of communication between the corporate business office and house manager around financial transactions.
CHD did not fully implement new policies
According to the DDS document, a review by the DDS Office of Quality Enhancement, the department’s provider licensure unit, found that as of September, CHD had not fully implemented new policies, oversight, or checks and balances that were adopted in January. The OQE recommended that CHD “improve its service delivery, with a focus on training and supervision of staff, healthcare coordination, and management of individuals’ benefits and personal spending money.”
The OQE also noted in the summary document that:
- Despite heightened focus over past 7 months, some individuals’ medical needs were still not being met.
- CHD’s Social Security representative payee and funds management procedures needed to be “thoroughly examined and modified.”
- Promising oversight mechanisms such as quality assurance audits had not been fully implemented.
- CHD needed to ensure that staff in key management and supervisory positions in Tim’s and the second CHD group home were “thoroughly knowledgeable of DDS regulations, policies, and licensing standards.”
Tim’s weight gain and subsequent medical diagnosis not reported
In August, in the wake of COFAR’s blog posts about the case, CHD announced that it had adopted a series of new policies to better manage and track care in its group homes, including a system to automatically inform family members and guardians of medical appointments and their outcomes. That new family information system was scheduled to be implemented in that same month, according to CHD.
However, Phaneuf said that in September, she noticed Tim had gained a considerable amount of weight in a short period. She said she met with Tim’s primary care doctor on September 10th and learned only then that in late July, Tim had been found to have gained 20 pounds and that medical lab tests had been ordered.
In an email sent to CHD officials on September 11, Phaneuf said the doctor told her the lab tests showed Tim was prediabetic and had hypothyroidism, and that he needed to be placed on a low-carbohydrate diet with daily exercise immediately. “I was not aware of any of this (prior to speaking to Tim’s doctor),” Phaneuf said.
Phaneuf said that after she contacted DDS and CHD about the situation, CHD failed to provide her with an outline of a proposed food or exercise plan. And at Tim’s Individual Support Plan (ISP) meeting in October, Phaneuf said she was informed that as of that date, no trainings had been scheduled for the staff regarding a low-carb diet or exercise plan for Tim.
Phaneuf said that while CHD said it would pay for Tim to see a nutritionist since his insurance would not cover one, Tim does not have the cognitive ability to adequately process nutritional counseling nor does he have control over his own food. CHD shops, cooks and serves food to Tim, she said.
In his January 3 email, Craft said that CHD could not comment “on specifics of individuals’ medical care.” His email added that, “however, CHD program and leadership staff have maintained regular communication with family members and guardians about medical care, and CHD has done everything possible to ensure all individuals’ health needs are met.”
Phaneuf never received written notice from DDS of the pending closure
Phaneuf said that in December, she was informed verbally by a DDS official of the termination of the CHD contract for Tim’s group home and the need for him to move to another residence. She said that as of Monday (January 6), she still had not received a written notice from DDS about either of those developments.
CHD a “large, multifaceted organization”
According to its online 2017 DDS licensure report, CHD is “a large, multifaceted organization” that “continues to maintain services throughout western Massachusetts as well as Connecticut.”
As of the start of the current fiscal year, CHD operated 23 DDS-funded group homes in Massachusetts, serving 76 clients, according to data from DDS.
CHD’s most recent online fiscal report to the state, which was for Fiscal 2018, showed that CHD received total operating revenues of $98.4 million primarily from a variety of state agencies, including $9.7 million from DDS.
Questions remain
While the contract termination action by DDS is welcome, it still raises a number of questions, including why the department’s provider licensure system itself did not identify the problems.
Little or nothing was initially done by DDS in response to Phaneuf’s concerns, and no investigations occurred until after COFAR posted about the case last July and there was subsequent coverage about it in The Springfield Republican.
COFAR has never gotten an answer from DDS as to why the normal DDS licensure review of CHD in 2017 did not flag any of the issues that Phaneuf subsequently raised. DDS, as ususal, appears to have reverted to its usual mode of not commenting or issuing any information in response to our queries that isn’t specifically required under the Public Records Law.
As we’ve said many times before, the problems finally identified regarding CHD are not unique to this one provider, but appear to be systematic across the entire DDS provider network. Over the past year, we have met with key lawmakers and with several state agencies, including the offices of the attorney general, inspector general, and state auditor to suggest the need for a comprehensive investigation of the DDS group home system.
COFAR blog 