Overview of the Community Care Services Program
Georgia’s Community Care Services Program (CCSP) provides home and community-based services (HCBS) for elderly and / or disabled state residents who are functionally impaired and at risk of nursing home admittance. Designed to prevent and / or delay the need for nursing home care, the benefits and supports encourage independent living. Benefits vary based on the needs and circumstances of a program participant but might include assistance with activities of daily living (ADLs) and instrumental activities of daily living (IADLs), such as mobility, eating, personal hygiene, shopping for groceries, and meal preparation. Personal emergency response systems, adult day care, and respite care are also potential benefits.
In addition to one’s home and the home of a loved one, program participants can reside in a personal care home, which is similar to an assisted living residence. However, program participants cannot reside in an adult foster care home.
The services offered under this program may be provided by licensed care workers, or program participants have the option to self-direct their personal care services via Personal Support Consumer Direction. This option allows a program participant to choose their own caregiver. However, unlike many state Medicaid waivers that allow persons to hire a relative, CCSP only allows it in extenuating circumstances, such as when one lives in an area so rural there are no traditional providers available. Even then, while an adult child can be hired, a spouse cannot be hired. A financial management services agency handles the financial aspects of employment responsibilities such as background checks, tax withholding, and caregiver payments. Persons residing in personal care homes cannot self-direct their care.
CCSP is not an entitlement program, which means meeting eligibility requirements does not equate to immediate receipt of program benefits. Instead, the waiver has a limited number of participant enrollment slots, and when these slots are full, a waitlist for program participation forms. A portion of these slots are reserved specifically for persons residing in nursing home facilities who wish to transition back to community living and some slots are reserved for persons with Alzheimer’s disease and related dementias.
The Community Care Services Program operates under Georgia’s Elderly and Disabled Waiver Program (EDWP), which is a 1915(c) Home and Community Based Services (HCBS) Medicaid Waiver. Another program, Service Options Using Resources in a Community Environment (SOURCE), also operates under the Elderly and Disabled Medicaid Waiver.
Historically Medicaid only paid for long-term care in nursing homes. 1915(c) HCBS Medicaid Waivers allow states to offer benefits outside of these institutions. “HCBS” stands for “Home and Community Based Services. The goal of HCBS is to delay or prevent institutionalization and to that end, care may be provided in one’s home, the home of a relative, assisted living, or adult foster care / adult family living. Waivers can target specific groups who require a nursing home level of care and are at risk of institutionalization such as the elderly, disabled, or persons with Alzheimer’s. Waivers are not entitlements. This means that meeting eligibility criteria does not guarantee receipt of benefits, as there are a limited number of slots for program participants.
Benefits of the Community Care Services Program
In addition to case management, the following long-term services and supports may be provided via CCSP. An individual care plan will determine which services and supports a program participant will receive. Personal care assistance may be self-directed, meaning one can select the caregiver of their choosing.
– Adult Day Health Care – supervised daytime medical care and specialized therapies (physical, occupational, or speech) in a community group setting
– Alternative Living Services – around the clock supervision and personal care assistance in a personal care home
– Financial Management Services – for program participants directing their own personal care
– Homemaker Services – assistance with shopping for essentials, preparing meals, and light housecleaning
– Meal Delivery
– Personal Emergency Response Services
– Personal Care Assistance
– Respite Care – in-home and out-of-home care to give a primary caregiver a break from caregiving duties
– Skilled Nursing – provided in-home
– Structured Family Caregiver – supportive services for family caregivers, such as over-the-phone counseling and health education
– Therapy Services – in-home physical, occupational and speech therapies
CCSP will not cover the cost of room and board in personal care homes.
Eligibility Requirements for the Community Care Services Program
CCSP is for Georgia residents who are elderly (65+) or younger if physically disabled that are at risk of nursing home placement. Additional eligibility criteria are shown below.
Financial Criteria: Income, Assets & Home Ownership
The applicant income limit is equivalent to 300% of the Federal Benefit Rate (FBR), which increases on an annual basis in January. In 2021, an applicant, regardless of marital status, can have a monthly income up to $2,382. When both spouses are applicants, each spouse is considered individually, with each spouse allowed income up to $2,382 / month. When only one spouse is an applicant, the income of the non-applicant spouse is not counted towards the income eligibility of his/her spouse. Furthermore, monthly income from the applicant spouse can be transferred to the non-applicant spouse as a spousal income allowance, also called a monthly maintenance needs allowance. The maximum amount that can be transferred in 2021 is $3,259.50 / month and is intended to ensure the non-applicant spouse has a minimum monthly income of this amount. Non-applicant spouses who have their own income equal to or greater than this amount are not entitled to a spousal income allowance.
In 2021, the asset limit is $2,000 for a single applicant. For married couples, with both spouses as applicants, the asset limit is $3,000. When only one spouse is an applicant, the assets of both the applicant and non-applicant spouse are limited, though the non-applicant spouse is allocated a larger portion of the assets to prevent spousal impoverishment. (Unlike with income, Medicaid considers the assets of a married couple to be jointly owned). In this case, the applicant spouse can retain up to $2,000 in assets and the non-applicant spouse can keep up to $130,380. This larger allocation of assets to the non-applicant spouse is called a community spouse resource allowance.
Some assets are not counted towards Medicaid’s asset limit. These generally include an applicant’s primary home, household furnishings and appliances, personal effects, and a vehicle.
Assets should not be given away or sold under fair market value within 60-months of long-term care Medicaid application. This is because Georgia Medicaid has a look back rule and violating it results in a penalty period of Medicaid ineligibility.
The home is often the highest valued asset a Medicaid applicant owns, and many persons worry that Medicaid will take their home. Fortunately, for eligibility purposes, Georgia Medicaid considers the home exempt (non-countable) in the following circumstances.
– The applicant lives in the home or has “intent” to return to the home and his / her home equity interest is no greater than $603,000. Home equity interest is the current value of the home minus any outstanding mortgage.
– A spouse resides in the home.
– The applicant has a dependent relative living in the home.
To learn more about the potential of Medicaid taking the home, click here.
Medical Criteria: Functional Need
An applicant must require an intermediate level of nursing facility level of care (NFLOC). For CCSP, an applicant must have a physical condition that results in a functional impairment and have a need for care that is not being met. Alzheimer’s disease and related dementias are considered qualifying physical conditions. The tool used to determine if one has an unmet need for care is the Determination of Need Functional Assessment-Revised (DON-R). One’s ability / inability to independently complete their activities of daily living (i.e., transferring from the bed to a chair, mobility, eating, toileting, eating) and instrumental activities of daily living (i.e., meal preparation, money management, housework) is considered when making this determination. Cognitive impairment, such as memory issues, which is often seen in persons with dementia, is also a consideration. The tool used to determine if the NFLOC need is met is the Minimum Data Set Home Care (MDS-HC) and is completed in-person by a nurse. With the MDS-HC, activities of daily living, instrumental activities of daily living, and cognitive ability are also considered. Furthermore, a physician must agree that a nursing home level of care is required. A diagnosis of dementia in and of itself does not mean one will meet the criteria for NFLOC.
Qualifying When Over the Limits
Having income and / or assets over Medicaid’s limit(s) does not mean an applicant cannot still qualify for Medicaid. There are a variety of planning strategies that can be used to help persons who would otherwise be ineligible to become eligible. Some of these strategies are fairly easy to implement, and others, exceedingly complex. Below are the most common.
When persons have income over the limits, Miller Trusts, also called a qualified income trust can help. “Excess” income is deposited into the trust, no longer counting as income.
When persons have assets over the limits, trusts are an option. Irrevocable Funeral Trusts are pre-paid funeral and burial expense trusts that Medicaid does not count as assets. Another option, but for persons with a significant amount of “extra” assets, are Medicaid Asset Protection Trusts. With this type of trust, assets no longer count towards Medicaid’s asset limit, but the trust must be implemented well in advance of the need for Medicaid long-term care. There are many other options when the applicant has assets exceeding the limit.
Inadequate planning or improperly implementing a Medicaid planning strategy can result in a denial or delay of Medicaid benefits. Professional Medicaid planners are educated in the planning strategies available in the state of Georgia to meet Medicaid’s financial eligibility criteria without jeopardizing Medicaid eligibility. Furthermore, there are additional planning strategies that not only help one meet Medicaid’s financial criteria, but can also protect assets for family as inheritance. These strategies often violate Medicaid’s 60-month look back rule and should only be done with careful planning. Medicaid planners are aware of some workarounds, and therefore, it is highly suggested one consult a Medicaid planner for assistance in qualifying for Medicaid when over the income and / or asset limit(s). Find a Medicaid planner.
How to Apply for the Community Care Services Program
Before You Apply
Prior to applying for CCSP, applicants need to ensure they meet the eligibility criteria. Applying when over the income and / or asset limit(s) will be cause for denial of benefits. The American Council on Aging offers a free Medicaid eligibility test to determine if one might meet Medicaid’s eligibility criteria. Take the Medicaid eligibility test.
As part of the application process, applicants will need to gather documentation for submission. Examples include copies of Social Security and Medicare cards, bank statements up to 60-months prior to application, proof of income, and copies of life insurance policies, property deeds, and pre-need burial contracts. Unfortunately, a common reason applications are held up is required documentation is missing or not submitted in a timely manner.
Since the Community Care Services Program is not an entitlement program, there may be a waitlist for program participation. The Elderly and Disabled Medicaid Waiver, under which CCSP is authorized, is approved for a maximum of 34,826 beneficiaries per year. At the time of this writing, there is a waitlist for CCSP benefits. An applicant’s placement on the waitlist is based on one’s need for supportive services. This means that in some cases, persons who submitted an application at a later date than other applicants may be awarded a participant slot first if their needs are greater. Applicants may also consider GA’s SOURCE Program, which does not currently have a waitlist.
To apply for the Community Care Services Program, persons should contact their local Area Agency on Aging (AAA). Contact information can be found here, or alternatively, persons can call 1-888-669-7195. A telephone screening will be done to establish if eligibility criteria might be met, and if so, the applicant will be placed on a waitlist for an in-home functional needs assessment. Placement on the waitlist is based on one’s unmet needs.
Applicants who are not already enrolled in GA Medicaid must apply for Medicaid via the Department of Human Services’ Division of Family and Children Services. An application can be downloaded here. Persons can also apply online at Georgia Gateway. One’s local AAA should be able to assist with the Medicaid application process. For additional information about CCSP, click here.
The Georgia Department of Community Health (DCH), along with the GA’s Area Agencies on Aging (AAA), administer the Community Care Services Program. Financial eligibility for CCSP is determined by GA’s Department of Human Services’ Division of Family and Children Services (DFCS).
Approval Process & Timing
The Medicaid application process can take up to 3 months, or even longer, from the beginning of the application process through the receipt of the determination letter indicating approval or denial. Generally, it takes one several weeks to complete the application and gather all of the supportive documentation. If the application is not properly completed, or required documentation is missing, the application process will be delayed even further. In most cases, it takes between 45 and 90 days for the Medicaid agency to review and approve or deny one’s application. Based on law, Medicaid offices have up to 45 days to complete this process (up to 90 days for disability applications). However, despite the law, applications are sometimes delayed even further. Furthermore, as there is currently a wait-list for CCSP, approved applicants may spend many months waiting to receive benefits.