Overview of the Community Attendant Services Program
Texas’ Community Attendant Services (CAS) Program provides non-medical personal care assistance, homemaker services, and transportation assistance to / from medical appointments for Texas residents who, due to health issues, have difficulty independently completing these daily living activities. The goal of this statewide program is to prevent and delay the need for nursing home care, instead allowing seniors and disabled individuals to live in their home or the home of a loved one. Services cannot be provided for persons living in assisted living residences or adult foster care homes.
There is flexibility of providers for persons receiving in-home assistance via the Community Attendant Services Program, as care services may be consumer directed. This means that rather than receive services by a licensed care provider, a program participant can hire their own “care attendant”. Formally called the Consumer Directed Services Option, certain relatives, such as one’s adult child or grandchild, can be hired. Spouses and parents cannot be paid for providing care. A financial management services agency handles the financial aspects of employment responsibilities such as background checks, tax withholding, and caregiver payments.
CAS is an entitlement, which means meeting eligibility requirements guarantees immediate receipt of program benefits. This means there is never a waitlist (interest list) for program participation.
The CAS program is one of a suite of services offered under the Community Care for the Aged and Disabled (CCAD) Program as an alternative to nursing home placement. The CCAD program provides a variety of non-Medicaid long-term services and supports, such as adult day care, meal delivery, emergency response services, and adult foster care services. CAS is unique in that it is Medicaid-funded, but is for persons who are not generally eligible for Medicaid. The eligibility criteria set forth for CAS is only for the services provided via this program. Put differently, meeting the CAS eligibility criteria makes one eligible for in-home care services provided via this program, but does not make one eligible for healthcare, which is traditionally provided by Medicaid.
Benefits of the Community Attendant Services Program
Program participants can receive the following services.
– Escort Services – provides assistance to / from doctor appointments
– Homemaker Services – housecleaning, laundry, shopping for essentials, meal preparation
– Personal Care Assistance – non-medical in-home assistance with bathing, grooming, dressing, toileting, eating, medication reminders, etc.
The maximum number of hours of assistance that can be provided is 50 per week.
Eligibility Requirements for Community Attendant Services Program
The Community Attendant Services Program is for Texas residents of any age who meet the eligibility criteria below. A quick TX Medicaid eligibility test is also available here.
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, a single applicant can have a monthly income up to $2,382, while a couple with both spouses as applicants is allowed up to $4,764 / month. If only one spouse is an applicant, first the applicant must meet the individual income limit of $2,382 / month, and second, the income of both spouses must be under the couple limit of $4,764 / month.
In 2021, the asset limit is $2,000 for a single applicant and $3,000 for a married couple. The asset limit for a couple holds true even if only one spouse is an applicant. However, 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.
While there is a 60-month look back rule in which Medicaid checks past asset transfers of those applying for nursing home Medicaid or home and community based services via a Medicaid waiver, this is not relevant for the Community Attendant Services Program. In other words, it is not applicable.
The home is often the highest valued asset a Medicaid applicant owns, and many persons worry that Medicaid will take their home. Fortunately, for CAS eligibility purposes, the home is generally exempt. In 2021, there is a home equity interest limit of $603,000 for applicants of Medicaid nursing home care and home and community based services via the STAR+PLUS Medicaid Waiver. Home equity interest is the current value of the home minus any outstanding mortgage. However, there is no equity interest restriction for the CAS Program. However, the home is not safe from Medicaid’s estate recovery program.
To learn more about the potential of Medicaid taking the home, click here.
Medical Criteria: Functional Need
An applicant must have a medical need for the services provided via the CAS Program. This is determined by an assessment yielding a functional impairment score. A set minimum score is required for program assistance. One’s ability / inability to independently complete activities of daily living (i.e., transferring from the bed to a chair, mobility, eating, toileting, eating) is considered. Applicants must require assistance with a minimum of one activity of daily living. Furthermore, a statement from a physician indicating an applicant has a medical need for care is required. While persons with Alzheimer’s disease or a related dementia often require assistance with such tasks due to cognitive decline, a diagnosis in and of itself does not mean one will meet the functional need.
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.
Utilizing Miller Trusts, often called qualified income trusts, is a common strategy used to lower an applicant’s monthly countable income for long-term care Medicaid eligibility. Essentially, “excess” income is deposited into the trust, no longer counting as income. However, Miller Trusts are not permitted for applicants to become income-eligible for the CAS Program.
When persons have assets over the limits, one option is to “spend down” assets. Examples include paying off debt, making home modifications for accessibility and safety purposes, and purchasing pre-paid funeral and burial expense trusts called Irrevocable Funeral Trusts. For persons who have low monthly income, another option is annuities, which turn countable assets into a stream of income. 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 Texas 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 from Medicaid’s estate recovery program for family as inheritance. 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 Attendant Services Program
Before You Apply
Prior to applying for the Community Attendant Services Program, 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 might need to gather documentation for submission. Examples include copies of Social Security and Medicare cards, 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.
To apply for the Community Attendant Services Program, applicants must be eligible for Texas Medicaid specific to this program. State residents should contact their local Texas Health and Human Services (HHS) agency to apply. Persons can find their local office here. Alternatively, persons can call the Aging & Disability Resource Center (ADRC) at 1-855-937-2372 for assistance. As part of the application process, an in-person interview will be completed. Very limited program information can be found here.
The Texas Health and Human Services Commission (HHSC), an agency within Texas Health and Human Services (HHS), administers the Community Attendant Services Program. It was previously administered by the Department of Aging and Disability Services (DADS). However, in 2017, DADS was abolished.
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.