ABI Waiver Archives


December 2015:  The Department of Social Services submitted formalized notice to the legislative committees of cognizance to inform the appropriate legislators of the Department's intention to amend the Acquired Brain Injury (ABI) and Acquired Brain Injury II (ABI II) Waivers to transition the case management services currently provided by department Social Workers to contracted entities that would be selected based on a competitive procurement. The selected contractors would address all participants' case management needs.

BIAC provided testimony at the 12/17/15 hearing supporting this amendment with the stipulation that there be additions to the language to include specific and clear language requiring brain injury training and experience. The legislators voted not to move forward with the proposal as currently written. The Committees voted down the proposed amendments and asked DSS to come back with a new proposal.  Another public hearing will occur within 30 days after DSS resubmits the amendments to the legislative committees.  BIAC will publish notice of the date of the hearing as soon as it is available.

Department of Social Services posted an Addendum to the Request for Proposals for Care Management for ABI Waiver Program on December 31, 2015 (original RFP issued on 10/30/15).  By clicking on 'Addendum', you can view the RFP in its entirety.  

On Tuesday, August 11th2015 there was a joint Human Services and Appropriations Committees legislative briefing & public hearing at the Legislative Office Building to discuss the proposed changes to Connecticut’s Acquired Brain Injury Waivers.  The committees made a motion to amend the cognitive behavioral services definition and payment rates on ABI Waiver I and ABI Waiver II and to amend the definition of Prevocational services on ABI Waiver I. The motion was passed. For further details see 'Summary of Amendments'. These changes were submitted to Centers for Medicare and Medicaid Services (CMS).  CMS approved the changes with an effective date of December 1, 2015. 

To view the public hearing on CT-N click the link below:

Appropriations and Human Service Committees Public Hearing and Meetings on ABI Medicaid Waiver Renewal and Amendments
Click here to view BIAC's testimony. 
View the original Notice of Intent to Amend the Acquired Brain Injury Waivers

Additionally, Public Act No. 15-154 AN ACT CONCERNING NOTIFICATION OF MEDICAID WAIVER AND MEDICAID STATE PLAN AMENDMENT PROPOSALS was approved on July 2, 2015It is a substitution for House Bill No. 6155. Title 17b of the general statutes was repealed and the language in the above Public Act has been substituted in lieu thereof.

BIAC received the following communication from Nancy Grano, Health Insurance Specialist with the Division of Medicaid and Children’s Health Operations.  "We wanted to follow up regarding your question about time limits for HCBS waiver prevocational services. This note confirms that guidance provided in the September 2011 Informational Bulletin, and most recently incorporated into the CMS HCBS Waiver Technical Guide (accessible at https://wmsmmdl.cdsvdc.com/WMS/faces/portal.jsp), indicates that CMS requires that a time limit be specified/defined in the waiver document. However, the time limit is set at the State’s discretion. With regard to Connecticut’s ABI II HCBS Waiver, CMS indicated that a maximum allowable time exceeding two years would not be considered appropriate without a justification. This means that a timeframe under two years would not require explanation, but timeframe above two years would require an explanation."

May 2015: Updated ABI Medicaid Waiver Factsheet

This fact sheet, created by Department of Social Services, includes a side-by-side comparison of ABI Waiver I and ABI Waiver II.  Additionally, there is a section for responses from DSS to comments and questions posed by beneficiaries and advocates.

March 2015: Memo on Status of ABI Waivers from Commissioner Bremby
Memo on Status of ABI Waiver

ABI Waiver Advisory Committee was established by Public Act No. 14-150

Past Meetings:

Wednesday, September 10, 2014 at 10:00 AM
Committee Members
Meeting Agenda

Thursday, December 11th, 2014 at 10:00 AM

REGARDING EMERGING ILST QUESTIONS & CONCERNS: As of January 1st, 2015 an independent ILST will no longer be considered self-employed. The ABI Waiver participant or conservator will become the ILST providers employer and the ILST provider will be the employee. This has generated many questions and confusion.

For clarification please contact:

Kathy Bruni
Manager Alternate Care Unit
Department of Social Services
Phone: (860)424-5177
Email: Kathy.a.bruni@ct.gov

Public Hearing on Medicaid Waiver Renewal and Amendments-Amendment to the DSS ABI I Waiver was held in October 2014.

The Brain Injury Alliance (BIAC) attended the Public Hearing at the Legislative Office Building. Due to the feedback the Department of Social Services (DSS) received, the proposed amendment that Cognitive Behavioral Services be conducted “in person and face to face” was removed until DSS is able to sit down with the providers of this service to determine how these changes will affect them moving forward. DSS staff indicated that over the course of the next month a meeting will be scheduled and the Department will reevaluate the originally proposed amendment based on the input they receive.

Please view the following link for CT-N coverage of the hearing

Hearing covered areas below:

  1. A proposed amendment to the Acquired Brain Injury Waiver
  2. The CT Transition Plan for Acquired Brain Injury Waiver Amendment

Further background information on proposed changes:

On January 16, 2014, the Centers for Medicare & Medicaid Services (CMS) issued a ‘Final Rule’ for home and community based services (HCBS) that requires states to review and evaluate home and community based (HCBS) settings, including residential and nonresidential settings. The rule became effective March 17, 2014. States are required to ensure all HCBS settings comply with the new requirements and analyze all settings where HCBS participants receive services to determine if current settings comply with the final rule. The Connecticut Department of Social Services (DSS) has created a draft Transition Plan to assess compliance with the HCBS settings rule and identify strategies and timelines for coming into compliance with the new rule.

  1. Notice of Intent (NOI) to amend Personal Care Assistance (PCA), CT Home Care Program for Elders (CHCPE) and Acquired Brain Injury (ABI) waivers
  2. BIAC Summary of Amendment Changes
  3. Connecticut Transition Plan for Acquired Brain Injury Waiver Amendment

Important News on ABI Waiver II: Approved by Center for Medicare and Medicaid Services (CMS) and effective as of December 1, 2014
CMS Letter of Approval for ABI Waiver II

Application for ABI Waiver II

History: BIAC had reviewed the ABI Waiver II document and submitted comments to DSS on September 8, 2014.

BIAC Commentary on Application for ABI Waiver II

BIAC's comments include encouraging DSS to create a manual similar to the DDS manual entitled. The comments reference the booklet- Understanding the CT Department of Developmental Services (DDS) Home and Community Based Services Waivers: An Introduction to Your Hiring Choices. It was suggested that this could be used as an outline for developing a consumer handbook for those on the Acquired Brain Injury Waiver who are hiring, directing and managing their private providers.

Previous Years:

Public Hearing on Medicaid Waiver Renewal and Amendments-Amendment to the DSS ABI I Waiver was held in October 2014.

In May 2014, the Brain Injury Alliance of CT (BIAC) responded to the Department of Social Services (DSS) post to the CT Law Journal;  Notice of Intent to amend sections of the 'DSS State of CT Regulations on the Subject Matter of the Acquired Brain Injury (ABI) Waiver Program'.

BIAC responded with a formal position statement.
BIAC Commentary on ABI Waiver Regulations
Additional Feedback Regarding ABI Waiver Regulations (June, 2014)
Additional Feedback Regarding ABI Waiver Regulations (July, 2014)

On January 16, 2014, the Centers for Medicare & Medicaid Services (CMS) issued a ‘Final Rule’ for home and community based services (HCBS) that requires states to review and evaluate home and community based (HCBS) settings, including residential and nonresidential settings. The rule became effective March 17, 2014. States are required to ensure all HCBS settings comply with the new requirements and analyze all settings where HCBS participants receive services to determine if current settings comply with the final rule. The Connecticut Department of Social Services (DSS) has created a draft Transition Plan to assess compliance with the HCBS settings rule and identify strategies and timelines for coming into compliance with the new rule.

BIAC responded with a formal position statement.

BIAC Commentary on ABI Waiver Regulations
Additional Feedback Regarding ABI Waiver Regulations (June, 2014)
Additional Feedback Regarding ABI Waiver Regulations (July, 2014)

Program Application

In February 2014, the Department of Social Services notified the Legislative Committee on Human Services regarding their intention to submit an ABI Medicaid Waiver II Application. DSS then submitted a new application to the Human Services and Appropriations Committees at the end of the month.‚Äč

In March 2014, the Human Services and Appropriations committees held a public hearing to discuss the ABI Waiver II application.

BIAC responded with a formal position statement and provided verbal and written testimony.

Brain Injury Alliance of Connecticut Position Statement

Julie Peters, BIAC Executive Director -- Testimony
Carrie Kramer, BIAC Brain Injury Services Director -- Testimony
Deb Shulansky, BIAC Director of Community Outreach & Support -- Testimony
Melinda Montovani, BIAC Brain Injury Specialist -- Testimony
Rachel Callan, BIAC Brain Injury Specialist -- Testimony
Sarah Raskin, Board Certified Clinical Neuropsychologist -- Testimony

After public input, the Human Services & Appropriations Committees voted to approve Substitute HB5402 amending the application for Acquired Brain Injury Waiver II.

In May 2014, the bill passed by consent. HB5402 was signed by the Governor June 2014. The application was submitted to Centers for Medicare and Medicaid Services (CMS) for final revisions and approval. CMS approved ABI Waiver II with an effective date of December 1, 2014.

Please contact the Brain Injury Alliance of Connecticut — general@biact.org or call 860-219-0291 with any questions.