Notes from the State Association Executives Call Today!

November 24, 2014

DOL Companionship Rule

  • The enforcement has been delayed by six months (from Jan 1, 2015 – to June 30, 2015) and then will not be “formal” for yet another six months; there has been no protection for companies from civil liability because the law is in effect.

 HCBS Definition of Community –

  • Campus like settings could still be problematic even if the individuals go out for day, medical, recreation, etc!

  • Campus residences (even if not paid for by HCBS) could prevent the receipt of HCBS for other services.