Overview
The Center for Human Development (CHD) is a private nonprofit corporation established January 5, 1972. CHD operates more than 80 programs and services across western Massachusetts and Connecticut. According to its website,
[CHD] provides a broad range of high-quality, community-oriented human services dedicated to promoting, enhancing, and protecting the dignity and welfare of people in need.
CHD offers programs to support a wide range of vulnerable populations, including families in need, children who have been abandoned, and people who have mental illnesses or disabilities. These programs include outpatient clinics, group homes for people with Down syndrome, foster care sites, and a large alternative high school. As of June 30, 2020, CHD had 1,728 employees; 310 of these employees worked with the Department of Mental Health (DMH) Adult Community Clinical Services Program, and 216 worked with the Department of Developmental Services’ (DDS’s) adult long-term residential programs, known as Meadows Homes programs.
According to CHD’s independent audit report for the period ended June 30, 2019, CHD’s total operating revenue for fiscal year 2019 was $104,937,152, and its total operating expenses for that year were $100,653,323. CHD’s main sources of funding are contracts with state agencies, including DMH and DDS. CHD contracts with DMH for adult community clinical services and with DDS for adult long-term residential services. During the period July 1, 2018 through June 30, 2020, CHD operated 32 group homes funded by DMH and 21 funded by DDS.
CHD’s DDS Representative Payee Function
When a new person served enters a DDS Meadows Homes program, the first step in the process is to assess the person’s needs and develop an Individual Service Plan (ISP). This assessment is conducted by a team that consists of the person; the person’s family or guardian; a service coordinator from DDS; the person’s doctors; and CHD personnel, including the house manager, program manager, program director, and vice president (VP) of Individual Program Services. The team creates an ISP that describes the level of service or assistance the person needs. If needed, the team develops a Money Management Plan (MMP) as part of the ISP process. The MMP describes the level of financial assistance the person needs. The team reviews ISPs and MMPs annually and whenever the DDS service coordinator makes changes. ISPs and MMPs are tailored to each person’s needs; there is no uniform plan. Once approved, the ISP is given to the house manager at the group home, where staff members are trained on the person’s needs.
If the ISP assessment of the person served determines that the person requires CHD’s representative payee services, CHD notifies the Social Security Administration (SSA) of a Meadows Homes program’s intent to act as a representative payee for the person served. After a Meadows Homes program receives approval from SSA, it develops a Representative Payee Monthly Financial Plan (RPMFP) and submits it to CHD’s Corporate Fiscal Department along with the SSA approval letter.
Upon receipt of an RPMFP, the Corporate Fiscal Department opens a checking account for the person served at CHD’s designated bank and submits a request to SSA to have the benefits deposited directly in the person’s account. Additionally, the RPMFP informs CHD’s corporate representative payee accountant of the amount of the benefit and type/s of payment (recurring and/or periodic) to be made to, or on behalf of, the person served. Recurring payments—payments made for the same amount on the same day each month, such as rent, charges for care, and personal spending funds—are made by the corporate representative payee accountant. For periodic payments, including utility or pharmacy bills that are mailed regularly, the corporate representative payee accountant initiates payment upon receipt of a bill. No other type of unplanned disbursement (manual payment) from the account of the person served is processed by CHD without a Representative Payee Check Request Form completed by a program supervisor and approved by a program manager. Changes to an RPMFP are permitted only after a program supervisor completes a Request to Amend the Monthly Financial Plan Form and submits it to the corporate representative payee accountant.
For each person served for whom CHD provides representative payee services, the Meadows Homes programs use a monthly Personal Funds Management Sheet (PFMS). This sheet is the record of personal spending funds received from the corporate representative payee accountant as well as expense details, which include date, description, and cost of each purchase. The CHD staff member who helped with a purchase must provide the original receipt to support the transaction and initial the transaction on the PFMS. A second CHD staff member must review and initial the recorded transaction.
At the end of each month, the program manager reviews the PFMS to ensure that purchases from personal funds were acceptable items and that the account balance is accurate (see Appendix for a chart of acceptable and unacceptable uses of personal funds). After completing this review and reconciling any issues, the program manager sends the PFMS and supporting receipts to the Corporate Fiscal Department. Each month, the Corporate Fiscal Department’s Compliance Team, established in late 2019, audits the financial transactions and accounting records for each person for whom CHD provides representative payee services. To report its findings, the Compliance Team prepares an Individual Funds Management Review and sends it to CHD’s chief financial officer, VP of Fiscal Services, and VP of Disability and Elder Services.
CHD’s DMH Representative Payee Function
When a new person served enters a DMH-funded group home program, the first step is to conduct an Adult Comprehensive Assessment (ACA). ACAs are reviewed annually and whenever a member of the program’s licensed clinical staff makes changes.
If the person’s ACA assessment determines that s/he requires CHD’s representative payee services, CHD obtains consent from the person served or the person’s guardian (if the person served is unable to sign) and notifies SSA of the program’s intent to act as a representative payee for the person served. After the program receives approval from SSA, it develops an RPMFP and submits it to CHD’s Corporate Fiscal Department along with the SSA approval letter.
Upon receipt of an RPMFP, the Corporate Fiscal Department opens a checking account for the person served at CHD’s designated bank and submits a request to SSA to have the benefits deposited directly in the person’s account. Additionally, the RPMFP informs CHD’s corporate representative payee accountant of the amount of the benefit and type/s of payment (recurring and/or periodic) to be made on behalf of the person served. Payments and changes to RPMFPs at DMH-funded programs are processed the same way as those for DDS programs.
Persons served at DMH programs generally have more independence with regard to funds for personal spending, and transactions do not need to be logged or initialed by staff members unless the ACA of the person served states that staff assistance is needed to manage funds for personal use. DMH-funded programs use the PFMS or a Client Spending Received Receipt to record checks for personal use that they receive from the corporate representative payee accountant. Like the PFMS, the Client Spending Received Receipt is a record of personal spending funds received. It includes the date, description, and amount of every transaction. The person receiving the funds must sign the PFMS or the Client Spending Received Receipt to confirm the receipt of funds.
Complaint Procedure
According to CHD’s Employee Handbook, all CHD staff members are responsible for upholding all people’s human rights, and staff members are trained in human rights and their programs’ (DDS’s or DMH’s) complaint procedures as part of CHD’s new employee orientation and site-specific training.
DDS
According to CHD’s “Meadows Homes Policy: Mandated Reporters to [the Disabled Persons Protection Commission, or DPPC],” when any Meadows Homes employee has reason to believe or suspect (including a “mere suspicion”) that there has been abuse or neglect by a caregiver or the death of a person served, the employee must immediately file a complaint with DPPC by calling the DPPC hotline. According to DPPC’s website,
DPPC protects adults with disabilities from the abusive acts or omissions of their caregivers through investigation oversight, public awareness, and prevention.
When a complaint is filed with DPPC, DPPC screens the complaint and conducts or oversees an internal investigation or assigns the investigation to another agency, such as DDS. When DDS receives a complaint from DPPC, the DDS senior investigator determines whether it should be dismissed, resolved without investigation, referred to the DDS regional director for administrative review, referred directly to DDS’s conflict resolution team (CRT) for review, designated as requiring investigation but deferred pending investigation by outside authorities, assigned to an investigator for active investigation, or referred to another state agency for review. When the DDS senior investigator makes a determination, s/he issues a disposition letter to the DDS regional and area directors, the alleged victim and his/her legal guardian, the chairperson of the CHD human rights committee (HRC), and the executive director or president of CHD. The disposition letter is intended to inform all parties of the status of the complaint. The CRT receives a decision letter at the end of a complaint investigation, or an administrative review report at the end of an administrative review, and reviews the final resolution for all complaints. The CRT uses decision letters, administrative review reports, and/or the results of its own investigations (for complaints referred directly to the CRT) to formulate resolution letters and complaint action plans.
CHD does not investigate complaints originating at its DDS group homes. However, after an investigation ends, CHD receives a resolution letter and complaint action plan from the CRT. The complaint action plan may include corrective action that CHD must implement and may also require CHD to provide a written response to the CRT.
HRC
CHD has contracts with DMH and DDS to run group homes and programs that provide services to these agencies’ clients. CHD must comply with state regulations that apply to DMH and DDS, including 104 CMR 28 and 115 CMR 3, respectively. These regulations require CHD to establish an HRC and to define the HRC’s membership composition and functions.
The HRC is an independent body, and its general responsibility is to help providers support, promote, and protect the human and civil rights of the people served by CHD, as well as to ensure that the interests of these people are protected in matters of allegations of abuse, mistreatment, or neglect. CHD’s HRC meets quarterly and requires a quorum of two members. All meeting minutes are documented, reviewed, and approved by the HRC’s members. During these meetings, the HRC reviews resolved complaints from people at CHD group homes and programs. This review involves a discussion of DDS and DMH complaint disposition and decision letters to determine whether the HRC agrees with the complaint resolution. The HRC also reviews instances of physical restraint, monitors human rights training, and makes recommendations for program improvements to CHD management. The HRC may file a complaint directly on behalf of a person served or appeal a written decision for a complaint.
CHD subcontracts with a local nonprofit to operate some of its DMH-funded programs and group homes. The subcontractor has its own HRC and is required to adhere to the same DMH complaint resolution regulations as CHD. CHD officials told us that they did not typically oversee the subcontractor’s complaint resolution process.
| Date published: | December 23, 2021 |
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