Chapter 7: IL Plan Development

Once an applicant has been determined eligible and certified for IL services and they are moved into Status 10 (i.e., plan development), joint planning may begin. The applicant is now officially an IL program client with an open IL case. Clients and where applicable their guardian, may choose to develop a formalized Independent Living Rehabilitation Plan (ILRP) or to simply identify IL objectives by completing a Waiver.

An ILRP must indicate the independent living goal and training objectives to be achieved, the services and training to be provided to meet those goals, and the anticipated duration of the plan and each service. The purpose of the ILRP is to clearly define the client’s goal, objectives and the services he or she will require to achieve their IL goal. It is a plan of action that must be reviewed with the individual at least once a year, and is, therefore, subject to future amendments and revisions. Emphasize to the client that it is not a legal contract and there is nothing about it which is legally binding on either the client or the agency.

The Rehab Act of 1998, as amended, gives individuals the option of waiving their right to develop a formal ILRP. With a Waiver Plan, the individual simply sets the IL objectives he or she wants to work on. The Waiver also receives a review with the individual at least once per year. It is not a legal contract nor is it legally binding.

A client who desires IL services will choose to receive services developed on an Independent Living Rehabilitation Plan (ILRP) or Waiver Plan. As part of the planning process, the ILR teacher is responsible to first discuss and administer an IL skills assessment. The skills assessment is a useful tool used during plan development. In conjunction with the IL Skills Assessment, other assessment factors can be included for consideration before discussing training objectives, such as:

• Adjustment to blindness
• Educational background
• IL skills
• Medical history and prognosis (impact of other disabilities like hearing loss, diabetic complications, or mental health)
• Need for aids and devices and training in their use
• Personal and family income
• Any other factors which might affect the IL outcome

Following the IL skills assessment and gathering of other pertinent assessment information, the ILR teacher shall discuss the results of the assessment in an informative and understandable manner.

Next, the client and ILR teacher will discuss the client’s goal and objectives based on assessed information as well as input from the client and/or his or her legal guardian. The ILR teacher will then offer plan options with the client, to include benefits to both plan options. The client will select which plan option will best assist them to achieve their desired IL goal. The client and ILR teacher will set specific, measurable, achievable, results-focused, and time-bound (S.M.A.R.T.) goal and objectives. The goal should be written in plain language and clearly define what is going to be done.

If the ILR Plan or formal plan is selected, there are several elements to consider including but not limited to the IL Plan Start and End Date, IL Goal Description, IL Services, IL Objectives, Criteria for Review & Evaluation and Review Date. When completing the following elements, the ILR teacher shall ensure the following topics are covered with the client:

ILR Plan Date:

1. The effective plan date is the day that it was entered into the case management information system.
2. The plan shall be scheduled no later than one year from the date of the plan
3. Plans may be amended with an extension when extenuating circumstances make this necessary.

IL Goal Description:

1. This information can be a brief description of an IL outcome such as “Increase independence in the home,” “Participate in family, social, and community activities,” or “Enhance communication.”

IL Services:

1. Select the service types that will best facilitate positive results for the client.

IL Objectives:

1. Objectives are discussed, and agreed upon and succinctly documented in a case note
2. Use of S.M.A.R.T. goal/objective planning approach (examples follow);
   1. Objective type is “communication”
   2. Description is “access print material”
   3. Status is “in progress” until met, not met, or dropped
   4. Date S.M.A.R.T objectives date set
   5. Date completed is documented at the time the objective is met, not met or dropped.

IL Criteria for Review & Evaluation used with the ILRP or Formal IL Plan:

1. Allows for client’s achievement(s) to be measured and recorded;
2. Sets forth time frames to complete goal/objectives;
3. Serves to hold all parties accountable for their parts in the plan;
4. Allows parties to determine if any revisions/changes are needed
5. Helps to determine when the goal and all objectives have been met and plan is completed.
6. The case note should delineate the number of trials agreed upon in partnership with the client before the ILR teacher will consider the objective met or not met.

ILR Plan Review

1. At least one review shall occur with the client prior to the end of the plan date.
2. The review date is set with both ILRPs and Waiver Plans.
3. The ILR teacher will document if satisfactory or unsatisfactory progress has been made during the period.
4. If it is learned that the client is deceased, the ILR teacher will conduct a plan review, document the review findings, and complete the review by case noting the findings before closing the case.
5. The closure amendment in the case of a client’s death need not be mailed unless the client had a guardian and that party requests a copy.

Note: The date of death should be used as the closure date in CMS and on paper file folder.

Obtain the client’s and/or his or her legal guardian’s signature to the IL plan.

1. See the Appendix T for the standard length of time relevant to case statuses, but cases should not remain in training status over 24 months. Exceptions to this should be documented in the case notes and be approved by the IL Program Administrator.

Waiver Plan

The Waiver Plan gives the client the option to waive his or her right to prepare and receive a copy of a formalized plan; however, the ILR teacher and client will agree on a set of training objectives. If the waiver plan is chosen, the client and ILR teacher will:

Discuss, agree, and document IL training objectives

Use the S.M.A.R.T. goal/objective planning approach (examples follow);

• Objective type is “communication”
• Description is “access print material”
• Status is “in progress” until met, not met, or dropped
• Date objectives set
• Date completed column is documented at the time the objective is met, not met or dropped.

Sign the plan to indicate both agree with the waiver plan.

While the client has waived his or her right to receive a copy of their written IL plan, the ILR teacher still has case management responsibilities under this type of plan similar to that of the formal ILRP. The S.M.A.R.T. goal approach is still required to ensure the client moves through his or her training plan with achievability in mind and in a timely manner.

The ILR or Waiver Plan must be developed within 90 days after the eligibility determination. If more time is needed to prepare the IL plan, the reason for the need must be thoroughly documented in a case note and prior approval must be obtained from the Supervisor.

The ILRP/formal plan or Waiver must be entered into the electronic CMS by the ILR teacher and reviewed as well as processed by the supervisor before training services may commence. The ILRP is mailed to the client. However, the Waiver Plan is not mailed due to the client’s waiving his or her right to develop a plan. If the client requests a copy, one can be provided.

Before the expiration date of an ILRP or a Waiver Plan and in partnership with the client, the following must be completed:

• Reviewed the plan with the client
• Determine if the overall goal has been achieved
• Determine what objectives have been met, not met or will be dropped
• Determine the following:
  1. Should the case be closed as rehabilitated (i.e., Status 26)?
  2. Should the case be closed, other reasons, after IL plan was initiated (i.e., Status 28)?
  3. Should the current plan be amended?
  4. Should the current plan date be extended and if so, for how long?
  5. Should the old plan be closed with a new one created due to major changes in the training needs?

Both plan types are to be reviewed at least annually, before a plan is amended, and before the respective case is closed. The plan must be moved from a Status 10 “Plan Developed” to Status 12 “Plan Completed.”

The client and the ILR teacher are responsible for researching and identifying the items or services required and considering comparable benefits if available. Comparable benefits should be sought to the extent feasible and used in each case prior to expending case funds. Full consideration must be given to any comparable benefits available, especially private insurance, Veteran’s benefits, Medicaid and Medicare, to meet the cost(s) of any purchased service except where the use of such benefits would delay the provision of services. Some authorizations are straightforward and require little investigation. Other purchases require extensive assessment and cost estimates or quotes.

The services planned under an ILRP or the IL Waiver are not always purchased by the Department. These services shall be planned to ensure that the client receives everything he or she needs to reach the IL goal. The need to explore and use comparable services is required for nearly all planned services. Exempt services include:

• Situations when using comparable benefits would delay the rehabilitation process or involve extreme medical risk to the client.
• The determination of extreme medical risk should be based on medical evidence provided by a qualified medical professional.
• Comparable benefits are not required for IL application, assessment for determining eligibility and IL needs, counseling and guidance, and referrals.
• The ILR teacher shall specify who will provide which services for the client and how those services will be provided. Since services are time-limited, the client and ILR teacher must decide on acceptable beginning and ending dates for each of the services and all dates must be specifically listed in the plan.

The process for authorization of goods and services and making IL Equipment Transfers is discussed further under Chapter 9.