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DADS Terminology


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CMS Waiver Report (formerly HCFA Waiver Report).
LOC Assessment form used for the DBMD and CLASS programs
The Client Assessment, Review, and Evaluation form used for the CBA, MDCP, and CWP waiver programs.
Adaptive Aids.
Area Agencies on Aging.
American Association on Mental Retardation.
Adjusted Average Per Capita Cost.
Adaptive Behavior Level.
Accessibility of Service
The relative opportunity for people in need to obtain relevant services.
Affiliated Computer Service.
American with Disability Act.
Activities of Daily Living.
Adult Foster Care. Services provided in a 24-hour living arrangement with supervision in an adult foster home for individuals who, because of physical, mental, or emotional limitations, are unable to continue independently functioning in their own homes.
One who is available to the consumer for assistance or support when needed.
Agreement Assignee
The waiver program provider to which a waiver program provider agreement is transferred.
Agreement Assignor
The waiver program provider from which a waiver program provider agreement is transferred.
Area Information Center.
Assisted Living Facility. Residences that provide a “home with services” and that emphasize residents’ privacy and choice. Residents typically have private locking rooms (only shared by choice) and bathrooms. Personal care services are available on a 24-hour-a-day basis.
Abuse, Neglect, Exploitation.
A Department of Family and Protective Services form used to complete a Client Abuse and Neglect Report.
Adult Protective Services.
Applicant - Provider
A person or business that is seeking to obtain a waiver program provider agreement.
An individual whose eligibility for waiver services is in the process of being determined. An individual becomes an applicant when he is next in line to fill a slot in the waiver program, a slot becomes available, and DADS has approved the filling of the slot. Further, DADS has notified the individual, and the individual has submitted the required application materials to DADS within a specified time frame.
Assignment of a waiver program provider agreement
The transfer of rights, interest, and obligations of the waiver program provider agreement from the program provider to another person.
Application Packet (provider)
The paper work received by a person representing an entity applying for certification to provide services for a state waiver program. The applicant receives one packet for each waiver program for which they want to provide services.
Balanced Budget Act.
Benefits Data Exchange. A matching of social security numbers to determine RSDI (Retirement, Survivors and Disability Income)? The BENDEX file is produced for the states by the SSA. The BENDEX is created from the Master Beneficiary Record (MBR). The primary purpose of the BENDEX is to assist the States in administering the Aid to Families with Dependent Children (AFDC) program and the Medical Assistance program.
Billing/Fiscal Monitoring. A division of legacy TDMHMR Medicaid Administration Department.
Behavioral Health Organization.
Budget Number
A two-digit number indicating the budget to bill against. This item is needed for block grant services.
A program in which the state pays Supplemental Medical Insurance (SMI) premiums for eligible Medicaid recipients.
Client Assignment and Registration System. Legacy MH/MR mainframe system that provides demographic and other data about individuals served by the Department
A unique identifier across CARE applications.
CARE Form 3652
CARE Form 3652. An assessment form created by legacy Texas Department of Human Services in the 1980s that is used to determine medical necessity and nursing facility reimbursement and certain waiver cost caps. The CARE Form 3652 is TX specific.
Community Attendant Service. Formerly known as the Frail Elderly or 1929 (b), CAS is a non-technical, non-medical attendant care service for recipients of all ages whose chronic health problems impair their daily living.
Case Manager
A DADS employee who is responsible for case management activities. Activities include eligibility determination, participant registration, assessment and reassessment of participant's need, service plan development, and intercession on the participant's behalf.
Cost Accounting Methodology.
Client Abuse Neglect Reporting System - The Department’s system that records abuse and neglect allegations. All state facilities and community centers are required to use CANRS.
Community Based Alternatives. A Medicaid waiver program that provides home and community-based services to aged and disabled adults as a cost-effective alternative to nursing facility care.
Community Care Contracting.
Community Care for Aged and Disabled replaced by the term Community Services (CS); umbrella for all Title XX and some Medicaid programs
Community Care Assessment Tool.
Comprehensive Care Program.
Community Contract Register.
Consumer Directed Services. A program that empowers consumers to make personal decisions related to the delivery of Personal Assistance Services and Respite Services within his or her current home and community-based program.
Catalog of Federal Domestic Assistance.
Children’s Health Insurance Program.
Critical Incident. An event relating to a physical condition or medical crisis where chemical restraint, personal restraint or mechanical restraint was utilized or where medical errors or serious injury occurred. This event is inconsistent with routine practice.
A request for payment of services from a provider for a single individual that consists of one or more types of services performed for the individuals and may span multiple months but cannot span fiscal years.
Community Living Assistance and Support Services. A Medicaid waiver program that provides community-based services as an alternative to Intermediate Care Facility/Mental Retardation (ICF/MR VIII) institutional care for people with developmental disabilities other than mental retardation.
Community Living Option.
Consumer Managed Personal Assistance Services. Financial intermediary services provided to eligible individuals who supervise or have someone who can supervise their attendant. Individuals are responsible for interviewing, selecting, training, supervising and releasing their attendants.
Claims Management System.
Allegation of a rights violation, a statement of dissatisfaction concerning any aspect of the service delivery system, including but not limited to the denial, reduction, or termination of a service, the way in which a service is provided, or the provisions of a contract, rule, or statute.
Compliance Principles
Policies that are predetermined by legacy TDMHMR and agreed to by a waiver provider that require compliance.
Component Code
An alphanumerical assignment used to identify a specific program provider; e.g., Andrews Center’s component code is 190.
Consumer Choice
Provided when there is a range of service options to meet the diverse needs of consumers. The degree to which consumers have choice must go beyond the range of service choices and include opportunities for consumers to decide when and where services will be provided, and how and by whom tasks will be performed.
Community-Based Services
Services designed to help people remain independent and in their own homes; can include senior centers, transportation, delivered meals or congregate meals site, visiting nurses or home health aides, adult day care, and homemaker services.
Community Services. The term replacing CCAD.
Advising on accessibility and availability of services, including: the waiting list for services, other appropriate resources, and relevant rights, rules, statutes on service provision and eligibility.
Consumer / Client / Individual / Person
An individual who has been determined eligible to receive waiver services, has enrolled in s waiver program, and receives waiver services.
Used interchangeably with agreement. A formal agreement with the Department that specifies services to be provided.
Contract Manager
The formal, written agreement between DADS and a provider agency to provide services to DADS participants eligible under this chapter in exchange for reimbursement.
Contract Number
A unique number that identifies a provider agreement/contract. This number is not duplicated across WCA or programs (except ICF).
Corrective Actions
An activity intended to correct an action.
Corrective Action Plan
An agenda developed by a waiver program provider containing activities intended to correct an action found out of compliance during a review.
Cost Ceiling
The upper limit set for an Individual Plan of Care.
Cost Effective
The estimated average annualized cost of the applicant's individual service plan for waiver services must not exceed a ceiling based on the waiver formula calculation.
Comptroller of Public Accounts.
Child Protective Services.
Crisis Intervention
A situation where a client is in need of immediate intervention for safety or health concerns.
Committee Substitute House Bill.
Children with Special Health Care Needs.
Consolidate Interest List.
Consumer Services and Rights Protection. A division of legacy TDMHMR whose function is to represent consumers and family members in the mediation and resolution of their concerns and complaints in relation to treatment, legal and basic rights and to assist persons in locating mental health and mental retardation services and other public and private resources.
Consolidated Waiver Program. A 1915(c) Medicaid waiver program that provides services to the aged, disabled, developmentally disabled, and persons with mental retardation as an alternative to institutional care in a nursing facility or intermediate facility for the mentally retarded (ICF-MR). Both children and adults are served. The program offers services to those individuals that qualify to achieve or maintain dignity, independence, individuality, privacy, choice, and decision-making ability. The program also offers services to prevent or reduce inappropriate institutional care by providing home-based care and other forms of less intensive care.
Department of Aging and Disability Services. The following services are regulated and provided by DADS: mental retardation services; state school programs; community care, nursing facility, & long-term care regulatory services; and aging services & programs.
Day Activity and Health Services. Facilities providing daytime services to individuals residing in the community. Services are designated to address the individual’s physical, mental, medical, and social needs. Services include the provisions of nursing and personal care, physical rehabilitation, noon meal and snaks, transportation, social, educational, recreational, and activities.
Dallas Area NorthSTAR Authority.
Department of Assistive and Rehabilitation Services.
Deaf Blind Multi-handicapped Association of Texas.
Deaf-Blind with Multiple Disabilities Program. A Medicaid waiver program that provides home and community-based services to people who are deaf and blind with multiple disabilities as a cost-effective alternative to Intermediate Care Facility the Mentally Retarded (ICF-MR/RC) institutional placement.
The settling of a question or case by an authoritative decision or pronouncement.
Developmental Disabilities
A severe and chronic disability manifested during the developmental period before the age of 22, which results in impaired intellectual functioning or deficiencies in essential skills.
Department of Family and Protective Services. Previously DPRS; the State of Texas department charged with protecting children, adults who are elderly or have disabilities living at home or in state facilities, and licensing group day-care homes, day-care centers, and registered family homes.
Discretionary Sanction
A sanction exercised at the reviewer’s discretion based on reasons bearing on the entity's professional competence, professional performance, or financial integrity.
Durable Medical Equipment.
Department of Mental Retardation.
Departmental Program Management Office.
Diagnosis Related Group.
Disproportionate share.
Department of State Health Services.
Due Diligence
The level of judgment, care, prudence, determination, and activity that a person would reasonably be expected to do under particular circumstances.
Dual Eligibles
Individuals who qualify for both Medicare benefits and Medicaid assistance. There are two types of dual eligibles: 1) those who receive full Medicaid benefits, and 2) those for whom Medicaid pays for all or part of the Medicare premiums, co-payments and deductibles.
Data Verification Criteria.
Extended Care Facility.
Early Childhood Intervention.
Employee Misconduct Registry.
Entitlement Program
The Medicaid entitlement acts as a "safety net" for eligible individuals in need. Medicaid spending is not limited to a fixed amount of funds nor are the benefits limited to a fixed number of beneficiaries. The Medicaid rolls often fluctuate in response to factors such as economic recessions and natural disasters. The Medicaid entitlement guarantees that eligible individuals have access to a minimum level of benefits regardless of the state in which they live.
Early Periodic Screening, Diagnosis and Treatment.
Equity of Access.
External Quality Review Organization.
Emergency Response Services. Services provided through an electronic monitoring system and used by functionally impaired adults who live alone or who are socially isolated in the community.
Early Warning System.
Fair Hearing
A hearing before a fair hearing officer giving the complainant the chance to have a decision reviewed.
Family Based Alternative
A family setting in which the family provider or providers are specially trained to provide support and in-home care for children with disabilities or children who are medically fragile.
Family Care.
Frail Elderly.
Federal Financial Participation.
Fee for Service.
Federal Fiscal Year.
Foster Grandparents Program.
Finalized Claim
A claim that has completed processing through the Claims Management System and has a paid or denied status.
Financial Eligibility
Income eligibility rules for certain individuals under home and community-based waivers.
Federal Medicaid Assistance Percentage.
FORM 2314
Consumer Satisfaction Interview.
FORM 3624
Termination, Reduction, or Denial of CLASS.
FORM 3650
Level of Care.
FORM 3652-A
Client Assessment, Review and Evaluation (Care).
FORM 6500
Individual Service Plan.
FORM 6501
Deaf-Blind Medicaid Interest List Form.
Federal Poverty Level.
Federally Qualified Health Center.
Federal Records Center.
Frail Elderly
Previous name for Community Attendant Services (CAS).
Food Stamps.
General Revenue (GR)
Monies that are collected by the state of Texas via taxes and other state-generated income.
Governor’s Office of Budget, Planning, and Policy.
Good Cause
A legally sufficient reason for a ruling or action.
House Bill.
Health Care Financing Administration (now CMS).
HCFA Common Procedural Coding System. A set of codes used by Medicare that describes services and procedures. HCPCS includes Current Procedural Terminology (CPT) codes for services not included in the normal CPT code list, such as durable medical equipment and ambulance service. While HCPCS is nationally defined, there is a provision for local use of certain codes.
Home and Community based Services. The Home and Community-Based Services Program operated by the department as authorized by CMS in accordance with §1915(c) of the Social Security Act. . There are also other federal, state and local dollars that fund home and community based services, including the Social Services Block Grant (SSBG), Older Americans Act (OAA), Education and Rehabilitation funds and State General funds.
HCS Case Manager
An employee of the program provider who is responsible for the overall coordination and monitoring of services provided to an individual enrolled in an HCS program.
Home and Community Support Services Agency.
Home-Delivered Meals.
Health Plan Employer Data and Information Set.
Health and Human Services.
Health and Human Services Commission. The State of Texas department that has oversight responsibilities for designated health and human services agencies and administers certain health and human services programs including the Texas Medicaid Program, and Children's Health Insurance Program
HHSC Ombudsman
A process to investigate complaints and mediate fair settlement.
Health Information Counseling and Advocacy Program.
Health Insurance Portability and Accountability Act.Title I protects health insurance coverage for workers and their families when they change or lose their jobs. The Administrative Simplification provisions (HIPAA, Title II) require the Department of Health and Human Services to establish national standards for electronic health care transactions and national identifiers for providers, health plans, and employers. It also addresses the security and privacy of health data.
House Joint Resolution.
Health Maintenance Organization.
Hospice. Medical, social, and support services for terminally ill individuals, with no known curative treatment options, who have a prognosis of less than six months to live.
House Research Organization.
Historically Underutilized Business.
Inter-Agency Contract.
Inventory for Client and Agency Planning. The ICAP is used to assess adaptive and maladaptive behavior and gather additional information to determine the type and amount of special assistance that people with disabilities may need.
Intermediate Care Facility for Persons with Mental Retardation. Institutional care and treatment for individuals with mental retardation with an onset date before 18 years of age.
Internal Control Number. A Claims Management System-assigned number to uniquely identify an accepted claim.
Interdisciplinary Team. A group of professionals, paraprofessionals and non-professionals who possess the knowledge, skill and expertise necessary to accurately identify the comprehensive array of the individual's needs and design appropriate services and specialized programs responsive to those needs; consisting of, at a minimum, the individual and LAR, HCS case manager, and a nurse.
Inter-Governmental Transfer.
In Home Family Support.
Institution for Mental Disease.
Imminent Danger
Exposure or vulnerability to impending health or physical harm.
An individual determined by DADS as eligible for LTC or community services. The individual may also be referred to as a “consumer” or a “participant”. In the case of a nursing facility, the individual my be referred to as a “resident”.
Individual Practice Association.
Individual Plan of Care. A document that describes the type and amount of each service component to be provided to an individual and medical and other services and supports to be provided through non-waiver program resources.
Individual Program Plan. The IPP includes services (types, units, frequency, duration, and cost) a participant receives. It also identifies non-waiver services that the participant accesses in the community.
Individual Service Plan. A written plan describing the assessments, recommendations, deliberations, conclusions, justifications and outcomes regarding the specific services provided to the individual by the program provider.
Interactive Quality Forum.
Information Technology. A division of DADS.
Informal Re-consideration
State review procedures made available in cases of non-renewal, denial, cancellation, or termination of the provider agreement for a HCS or TxHmL waiver program provider.
Intermittent Review Reason
A code that represents the reason an intermittent review was held. The values are: complaint, DFPS report, and other concerns.
Joint Application Development. A system development methodology that involves the client or end user in the design and development of an application, through a succession of collaborative workshops called JAD sessions.
Local Authority.
Legally Authorized Representative. A person authorized by law to act on behalf of a person in a waiver program and may include a parent, guardian, or managing conservator of a minor, or the guardian of an adult.
Legislative Budget Board.
Local Behavioral Health Authority.
Large ICF/MR
A non-state operated ICF/MR with a Medicaid certified capacity of 14 or more.
Level I Sanctions
A sanction that is imposed when available evidence indicates the contract is in non-compliance with 12-23 principles at the time of the exit conference. Discretionary Level I Sanctions can be imposed when available evidence indicates the contract is in non-compliance with fewer than 12 principles at the time of the exit conference, but the non-compliance is of a serious or pervasive nature. Requires an on-site follow-up review by Waiver Survey and Certification 30-45 days from the exit conference of the review where Level I Sanctions were imposed. If all items are not corrected at the time of the follow-up review, vendor hold is initiated, and a second on-site follow-up review is conducted by Waiver Survey and Certification 30-45 days from the initiation of vendor hold. If all items are not in compliance at the time of the second follow-up, de-certification of the contract is initiated by Waiver Survey and Certification.
Level II Sanctions
A sanction that is imposed when available evidence indicates the contract is in non-compliance with 24 or more principles at the time of the exit conference. Discretionary Level II Sanctions can be imposed when available evidence indicates the contract is in non-compliance with fewer than 24 principles at the time of the exit conference, but the non-compliance is of a serious or pervasive nature. Results in vendor hold. Requires an on-site follow-up review by Waiver Survey and Certification 30-45 days from the initiation of vendor hold. If all items are not in compliance at the time of the follow-up, de-certification of the contract is initiated by Waiver Survey and Certification.
Amount of assistance required by consumers which may determine their eligibility for programs and services. Levels include: protective, intermediate, and skilled.
Local Mental Health Authority.
Level of Care. Texas Index for Level of Effort. Eleven-category case-mix system to determine nursing facility and certain waiver program reimbursement and cost-caps. Unique case-mix system developed in TX based on 1987 data and implemented on April 1, 1989. Current data do not reflect changes in practice patterns and resident characteristics over the past two decades. Data are derived from the CARE Form 3652. LOC is the criteria used to determine the extent of the consumer’s need for services and in the HCS and TxHmLwaivers is based on data submitted on the MR/RC Assessment.
Letter of Intent.
Local Case Number
An identifier assigned by the provider for a consumer for whom they provide services.
Location Code
A code that identifies where the consumer resides.
Level of Need. Range of medical and/or social services designed to help people who have disabilities or chronic care needs. Services may be short or long term and may be provided in a person's home, in the community, or in residential facilities (e.g., nursing homes or assisted living facilities). In the TxHmL and HCS waivers LON is derived from the service level score obtained from the administration of the Inventory for Client and Agency Planning (ICAP) to the individual and from selected items on the MR/RC Assessment.
Level of Service
The level of effort necessary for a provider to provide service to an individual. The level of service is a factor in determining the payment rate for services to the individual. Level of service includes level of care, level of need, and priority status.
Long Term Care. Long-term care is provided to persons who require assistance with health care and/or activities of daily living because of ageing or `a chronic physical or cognitive disability.
Long Term Care-Regulatory.
Long Term Care Services.
Medicaid Administration Claiming.
Medical Assistance Only - Provides medical coverage for individuals who are age 65 and over, blind or disabled, but do not receive monthly cash benefits under the Supplemental Security Income program.
Medical Care Advisory Committee.
Medicaid/CHIP Division.
Managed Care Organization.
Medically Dependent Children’s Program. A Medicaid waiver program that provides a variety of services to support families caring for children who are medically dependent, and to encourage deinstitutionalization of children in nursing facilities.
Minimum Data Set. A federally required functional assessment and care-planning document mandated by the Omnibus Budget Reconciliation Act of 1987 (OBRA 87). While created specifically as an assessment and care-planning tool, it has evolved into a reimbursement form. The foray into payment was the development of the Prospective Payment System (PPS) for Medicare skilled nursing facility residents. A number of states use this document to determine Medicaid nursing facility reimbursement through the RUGS methodology.
Multiple Disabilities Unit (State Hospitals).
A federal program, jointly funded by the states and the federal government, that reimburses hospitals and physicians for providing care to qualifying people who cannot finance their own medical expenses.
Medicaid Number
A unique identifier assigned to all Medicaid recipients.
Medicare Part A
The program that typically pays for your inpatient hospital expenses.
Medicare Part B
The program that typically covers your outpatient health care expenses including doctor fees.
Medicare Part C
Medicare Programs that provide for managed care plans; preferred provider organization (PPO) plans; private fee-for-service plans; or specialty plans.
Medicare Part D
The Medicare prescription drug coverage program.
Mental Retardation/Related Condition Assessment
A form used by the Department for LOC determination and LON assignment.
Mental Retardation
Significantly sub average general intellectual functioning that is concurrent with deficits in adaptive behavior and originates during the developmental period .
Medicaid Fraud Control Unit (a division of OIG).
Mental Health.
Mental Health Authority.
Mental Health and Mental Retardation (Legacy state agency).
Management Information System.
Medicaid Management Information System.
Medical Necessity. A determination made on each individual seeking Medicaid long-term care support and services. The federal government requires that each state operationally define a level that is a pre-determined threshold to receive services/supports.
Medicaid Program Integrity (a division of OIG).
Memorandum of Understanding.
Mental Retardation.
Mental Retardation Authority.
Mental Retardation/Development Disability.
Mental Retardation Local Authority.
Metropolitan Statistical Area. Metropolitan areas organized around county boundaries.
Medicaid Statistical Information System. Refers to standards set by Medicare/Medicaid for the transmission of electronic data.
Medical Transportation Program.
Multiple Disabilities
A person is considered to have multiple disabilities if, in addition to deafness and blindness, he or she has one or more disabilities that result in impairment to independent functioning. The person's adaptive behavior level must be rated 2 or greater. As a result, he or she must not be capable of living independently without substantial support.
Nurse Aide Registry and Nurse Aide Training and Competency Evaluation Program.
National Core Indicators. NCI produces a consumer survey used to identify and measure core indicators of performance of state developmental disabilities service systems.
Nursing Facility. The nursing facility program provides nursing care and appropriate rehabilitative/restorative services to eligible Medicaid recipients.
Nursing Facility Administrator.
Non-waiver Services
Services that are not provided under waiver provisions of Section 1915 (c) of the Social Security Act.
Texas' managed care program for behavioral health services that was implemented in 1999 for Dallas and contiguous counties. NorthSTAR integrates Medicaid-funded and public, non-Medicaid funded mental health and chemical dependency services. The program includes state and federal Medicaid funds (through a 1915 (b) waiver), non-Medicaid state and federal funds, and some county funds. NorthSTAR behavioral health services are "carved out" (not included in) the STAR program in the Dallas service area.
Office of the Attorney General.
Outcome and Assessment Information Set.
Omnibus Budget Reconciliation Act. Federal Omnibus Budget Reconciliation Act of 1981 created the 1915 (c) waiver programs. Federal Omnibus Budget Reconciliation Act of 1987 reformed rules for nursing facilities participating in Medicare and Medicaid. Federal Omnibus Budget Reconciliation Act of 1990 (OBRA ’90) created the Frail Elderly Program. HB 2292 renamed this program the Community Attendant Services (CAS) program.
Office of Early Childhood Coordination.
Office of General Counsel.
Office of Health Services.
Older Americans Act.
Office of the Inspector General.
Occupational Therapy.
A statistical term that refers to a data point that is located far from the rest of the data. Given a mean and standard deviation, a statistical distribution expects data points to fall within a specific range. Those that do not are called outliers and should be investigated.
Prior Authorization.
Program of All Inclusive Care for the Elderly. Provides community-based services to frail elderly people who qualify for nursing facility placement. PACE uses a comprehensive care approach providing an array of services for a capitated monthly fee this is below the cost of comparable institutional care.
Personal Assistance Service. Non-technical attendant care services provided to eligible persons functionally limited in performing activities of daily living. PAS are provided through the Primary Home Care Program.
Pre-application Orientation - An eligible applicant interested in becoming a waiver program provider, must attend the waiver program provider pre-application orientation (PAO) prior to receiving a program provider application packet.
Pre-Admission Screening and Annual Resident Review.
Pharmacy Benefits Management.
Primary Care Case Management.
Primary Care Physician.
Provider Claims Services.
Preferred Drug List.
CMS uses the quality indicators to identify potential performance problems. That is, CMS advises nursing facilities to look for quality problems whenever an indicator condition is more common in that facility than in 90% of all other facilities. For three of the indicator conditions (Dehydration, Fecal Impaction, and Pressure Sores in Low Risk Residents), CMS recommends looking for quality problems on every occurrence. The PDS rates each facility based on the number of indicator conditions that suggest potential performance problems - each such condition is a potential disadvantage for residents in that facility. The most favorable PDS rating means that a facility has the fewest potential disadvantages.
Person Directed Plan. A plan developed for a service applicant that describes the supports and services necessary to achieve the desired outcomes identified by the applicant or LAR.
Per Authorization Unit Type
Units approved to equal the cost of the authorized service. This authorization type is associated with the unit rate of one dollar.
Permanency Planning
A philosophy and planning process that focuses on the outcome of family support by facilitating a permanent living arrangement, with the primary feature of an enduring and nurturing parental relationship.
Person-Directed Planning 
A process that empowers the individual to direct the development of a plan of supports and services that meets the individual's goals. The process: identifies existing supports and services necessary to achieve the individual's goals; identifies natural supports available to the individual and negotiates needed service system supports; occurs with the support of a group of people chosen by the individual, or their representative; and mirrors the way in which people without disabilities make plans.

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