October 13th, 2020
Adult Programs Division
California Department of Social Services
744 P Street
Sacramento, CA 95814
CMIPSII-Requests@dss.ca.gov
Via Email
Re: Comments on draft ACL re: Modifications to the Disaster Preparedness Screen in the Case Management, Information and Payrolling System and the Disaster Preparedness Data Download File
Dear Ms. Miguelino,
Disability Rights Education and Defense Fund (DREDF) and Justice in Aging submit the following comments regarding the draft All County Letter (ACL) entitled Modifications to the Disaster Preparedness Screen in the Case Management, Information and Payrolling System (CMIPS) and the Disaster Preparedness Data Download (DDL) file.
DREDF is a national disability rights law and policy organization by and for people with disabilities that advocates to ensure equal access across a multitude of areas including emergency planning and response, health care, transportation and housing. DREDF’s emergency planning and response work particularly focuses on ensuring state and local jurisdictions meet their disability and access and functional needs (“AFN”) obligations in all phases of an emergency event with an emphasis on the areas of alerting, communications, evacuation, transportation, and sheltering. Justice in Aging is a national nonprofit that uses the power of the law to fight senior poverty by securing affordable health care and economic security for older adults with limited resources.
We have the following comments regarding the draft ACL.
CMIPS Modifications, Disaster Preparedness Screen, Disaster Preparedness Information Cluster, Degree of Contact pg. 3-4 – We propose that CDSS provide guidance on the definitions of “critical”, “urgent”, and “moderate” so the County worker is able to select the necessary degree of contact during the screen. This clarification is necessary because identifying the correct degree of contact is fundamental to enabling Counties to determine how to prioritize the needs of this population during an emergency. Providing definitions in plain language will also give county workers a resource for their own use since they must be able to clearly explain the categories to IHSS consumers before beneficiaries can make an informed decision to decline contact. We also suggest the guidance include the situation where an IHSS consumer relies primarily on a particular family member/IHSS worker who could, particularly in an emergency situation, be unavailable. An IHSS consumer who lives with an aging spouse or parent, for example, may think that no contact is required but may choose “moderate” or another category when encouraged to consider their needs if a live-in family member is away from the home or becomes injured themselves during an emergency.
CMIPS Modifications, Disaster Preparedness Screen,Electricity and Life Support Supply Needed Cluster, pg. 3-4 – We propose adding an “other” field with the option to fill in a response. We also propose adding the following life support supply options: “hospital bed”, “electric wheelchair”, and “communication equipment”. There are a number of medical devices not included in the screen that utilize electricity to sustain life and critical function. The addition of an “other” field would allow the County to fill in additional devices not listed on the screen. Furthermore, because hospital beds and electric wheelchairs are highly utilized life support supplies, adding these categories to the screen would also assist Counties to prioritize the needs of this population, and to identify and appropriately respond to IHSS recipients in the event of an emergency. Lastly, because some individuals with developmental and/or speech-related disabilities are fully capable of engaging with emergency personnel and will wish to do so, but will require the use of their personal communication devices. Therefore, including these devices will further increase access to local disaster response programs.
CMIPS Modifications, Disaster Preparedness Screen, Other Emergency Services Considerations cluster, pg. 6 – We propose adding a field called “emergency communications” with the option to fill in a response for preferred communication method. Being able to effectively communicate with people with disabilities is necessary to responding to their needs during an emergency and currently, there is no mandatory emergency alerting method for this population. Furthermore, people with disabilities utilize different kinds of communications methods to make emergency communications accessible to them, including texting with cell phones, voice messaging with cell phones and landlines, social media messaging, and radio communications. Adding an emergency communications field will assist Counties to respond to IHSS recipients in the event of an emergency. We also suggest adding the field “elevator” to indicate whether the person relies on an elevator that will have the potential to lose power during multiple emergencies. Currently, there is no County repository for this information and lack of access to an elevator during an emergency can be life threatening. Access to this information would increase the Counties ability to respond to meet the needs of this population.
In addition to the specific CMIPS changes above, we recommend that the Disaster Preparedness reporting workgroup reach out to the Department of Health Care Services to make this information consistently available to them as well. In an emergency, DHCS plays a key role in authorizing replacements for needed durable medical equipment and devices such as wheelchairs, ventilators and communication devices. The information collected on the Disaster Preparedness Screen and maintained on CMIPS could help a Medi-Cal beneficiary establish their need for emergency equipment when healthcare providers cannot be reached quickly or become difficult to access.
We commend CDSS, CWDA, and county program staff for developing these protocols and we hope that our recommendations will be given full consideration.
Sincerely,
Sydney Pickern, Staff Attorney
Claire M. Ramsey, Senior Staff Attorney