Overview
DDS did not ensure that necessary policies and procedures were in place to ensure that all recipients of DDS services enrolled in individual support plans (ISPs) have the opportunity to elect the self-determination option. Specifically, for 16 (21%) of the 75 recipients of DDS services in our sample, the self-determination option was not present within DDS’s web-based system.
The absence of the required self-determination option calls into question whether the proper quality of care was given to each recipient of DDS services who enrolled in an ISP.
Authoritative Guidance
Section 19 of Chapter 255 of the Massachusetts General Laws states,
(b) The department shall offer self-determination as an option to all individuals eligible for services through the department. Self-determination shall be based on the participant’s judgment and preferences as set forth in the participant’s person-centered plan. . . .
(f) Participation in self-determination shall be available to any individual who receives services from the department. . . .
(g) Participation in self-determination shall be voluntary. An individual may choose to take part in or seek other department services at any time; provided, that the individual budget shall follow a participant who seeks other department services. The department shall not require or prohibit participation in self-determination as a condition of eligibility for, or delivery of, services, supports or goods otherwise available.
Reasons for Issue
There are DDS providers that do not have access to DDS’s web-based system, so self-determination cannot be documented. While some providers have their own procedures for documenting the self-determination options, DDS is unaware of those recipients.
Recommendation
DDS should collaborate with providers and implement standardized policies and procedures to ensure that DDS is aware that all recipients of DDS services have been offered the self-determination option and are aware of who selected the self-determination option.
Auditee’s Response
DDS agrees with OSA’s recommendation to implement standardized policies and procedures to ensure that all recipients of DDS services who are eligible for self-directed services and not already engaged in self-direction have been offered the opportunity to self-direct their services.3 DDS acknowledges that it was not able to produce documentation in a number of the OSA sample cases, either from [DDS’s web-based system] or other DDS information systems, that confirmed an individual was informed (or re-informed) of the self-direction option during the audit review period. In response to this finding, DDS will reissue guidance to all service coordinators detailing the requirement to share information about self-directed services when sending the ISP invitation letters to all individuals on their caseload who are eligible for but not already self-directing services. DDS will maintain documentation of the requirement to discuss self-directed service options in its information system of record.
At present, all DDS staff are mandated to take annual training about self-determination and the value of self-directed services for eligible individuals who are interested. Offering self-direction to all eligible individuals is a high priority for the Department, in addition to growing the self-directed services that operationalize self-determination.
While DDS agrees with the overall audit finding, DDS would like to offer the following clarifications. First, [in the introduction section of Finding 5], OSA concludes that, “[t]he absence of the required self-determination option calls into question whether the proper quality of care was given to each recipient of DDS services who enrolled in an ISP.” DDS disagrees with OSA’s conclusion. On the contrary, there is no evidence that this one factor indicates the presence of the other. Person-centered planning and completing the ISP process at a high level of quality are a central part of the DDS service coordination work mandated by DDS regulations and the 1915c Home and Community Based Services waivers.
Second, [in the “Reasons for Issue” section of Finding 5, OSA finds that, “[t]here are DDS providers that do not have access to DDS’s web-based system, so self-determination cannot be documented.” DDS disagrees with this finding and reiterates that [Section 19 of Chapter 19B of the General Laws] requires DDS, not the service provider, to provide individuals with information about self-direction.
[Footnote:]
3. As a point of clarification, DDS notes that self-determination happens throughout our interactions with the individual in person-centered planning, development and implementation of the ISP. “Self-direction” is the service model that operationalizes self-determination.
Auditor’s Reply
In its response, DDS disagrees with the reason that led to this finding as stated in the “Reasons for Issue” section. However, the reason reported in this section was stated to us by DDS in two separate meetings, one on April 9, 2025 and the other on June 2, 2025. In addition, DDS disagrees that the absence of the required self-determination option calls into question whether the proper quality of care was given to each recipient of DDS services who enrolled in an ISP. To clarify, we are not stating that DDS delivered poor quality of care, but rather, we are stating what the possible effect of this issue could be and the importance of offering the self-determination option to all its recipients enrolled in ISPs.
Nevertheless, DDS agrees with the remainder of our finding and is taking measures to address our concerns regarding this matter. As part of our post-audit review process, we will follow up on this matter in approximately six months.
| Date published: | April 15, 2026 |
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