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.