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The 2019 DDS Services Rate Study provided a solid roadmap to evaluate service provider rates, but the study also included an error when it assigned rates to Independent Living Services, known as ILS. ILS service providers are skilled life coaches and instructors, teaching people with I/DD how to live independently in a safe, supported, and person-centered environment. As the person with I/DD learns more skills, they can lead more independent lives and reduce their reliance on other support services. But the Burns Rate Study misclassified these ILS Direct Support Professionals, essentially reducing their compensation rates to that of lower skilled workers like personal care aides.

This mistake directly contradicts the Health and Welfare Code 17 CCR § 56742, which clearly outlines the skill level required for ILS workers. The LAO noted the error in a 2019 letter:

“…Since the ILS services focus more on functional skills training than personal care, the wage assumptions underlying the rate model for ILS may need to be adjusted upwards if the desire is to accurately reflect actual costs.” – LAO Letter, 2019

“ILS actually receives an aggregate rate decrease under the proposed rate model. This implies that ILS is potentially overfunded. However, we also know that ILS will be a particularly important service as more consumers hope to live on their own and the state must come into compliance with the HCBS rules. If a rate decrease has the effect of reducing access to, or the quality of, ILS services, this could work against the state’s ultimate goals.” - LAO Report, 2019

Why This Matters:
While most DDS service provider rates are being raised to reflect the Burns Rate Study, and to reflect current provider costs more accurately, the ILS misclassification means higher skilled instructors are being left behind, receiving a fraction of the pay their skill level warrants.

Unintended Consequences:
  •  ILS programs are closing across the state, forcing consumers into more expensive levels of care or putting them on waiting on lists to access ILS services.
  • People with I/DD are not receiving the level of instruction they need and deserve to live a higher quality, independent, person-centered life.
  • Consumers are being forced to use services that don’t fit their needs as ILS becomes unavailable due to agency closures and staff shortages.
  • California is directly contradicting its own Health and Welfare Code 17 CCR § 56742.
  • Measurable Outcomes cannot be achieved.

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* 1. Contact Information

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* 2. Have you previously or currently provide ILS? 

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