NADDP Quick Reference Guide Module 7: Policy & Compliance

Segment 1: Federal Policy and Compliance Standards for Delivering Aging & Adult Services

Learning Objective:

  • Orient the Director to federal policy and compliance requirements.
  • Summarize key federal policies related to aging and disability services.
  • Analyze federal frameworks that support long-term services and inform local decision-making.
  • Identify roles of federal agencies (ACL, CMS, DOJ, EEOC).

Key Content:

  • Federal Context: Decentralized system shaped by federal, state, and local governance.
  • Population Overview:
    • Older Adults: diverse needs, independence, caregiver support, equity.
    • People with Disabilities: shift from medical model to inclusion.
  • Major Federal Laws & Programs:
    • Americans with Disabilities Act (ADA, 1990).
    • Age Discrimination Act (1975).
    • Civil Rights Act (1964, Title VI).
    • Elder Justice Act (2010, APS framework).
    • Medicare & Medicaid (1965, Titles XVIII & XIX).
    • Older Americans Act (1965, national aging services network).
    • Olmstead v. L.C. (1999, community-based living rights).
    • Guardianship Bill of Rights Act (proposed, 2023).
    • Uniform Guardianship Act (UGCOPAA, updated 2020).
  • Agencies: ACL, CMS, DOJ, EEOC, OCR.
  • Recent Developments:
    • May 2024 ACL Final Rule for APS compliance standards.
    • FY2026 proposal to reorganize ACL programs under ACFC.

Activities:

  • Federal Knowledge Check (multiple choice questions on laws/programs).
  • Discuss reasons for the lack of a federal older adult services system.
  • Review materials: Medicare/Medicaid Act, OAA summaries, ADA enforcement, Elder Justice Act, Guardianship Bill of Rights Act.

Coaching Session:

  • Discuss the Director’s role in understanding federal policy.
  • Reflection questions: surprises, similarities/differences, skills needed, action steps, timetable.
  • Agency reflection: embedding mission-driven values in compliance.
  • Wrap-up: strengths, worries, next steps.

Segment 2: Alignment of California Departments and Programs with Federal Regulations

Learning Objective:

  • Identify California’s key departments/programs in aging and adult services.
  • Describe foundational federal policies (OAA, Medicaid HCBS, ADA, Olmstead).
  • Explain how California programs align with federal mandates.

Key Content:

  • State System Overview: Multi-agency, community-based network under CalHHS.
  • CalHHS: Central hub for health, social services, aging, public health, behavioral health. Leads initiatives like Master Plan for Aging.
  • Key Departments:
    • California Department of Aging (CDA): administers OAA, OCA, Medi-Cal services via 33 Area Agencies on Aging (AAAs).
      • Services: Information & Referral (I&R), Aging & Disability Resource Connections (ADRCs), HCBS referrals.
      • HCBS programs: IHSS, MSSP, ALW, CBAS.
    • California Department of Social Services (CDSS): oversees APS and IHSS, sets policy, guides counties.
    • Department of Health Care Services (DHCS): Medi-Cal compliance.
    • Department of Rehabilitation (DOR).
    • Housing & Homelessness Division (HHD).
  • Superior Courts: Probate jurisdiction (wills, estates, guardianships, conservatorships).

Activities:

  • Review CDA Program Overview Fact Sheet.
  • Review AAA State Data Report.
  • Compare federal and state program structures.

Coaching Session:

  • Discuss alignment of California programs with federal mandates.
  • Reflection questions: strengths, worries, next steps.

Segment 3: Alignment of county and local programs with California laws and regulatory frameworks

Learning Objective:

  • Identify key California legal codes and regulations for county and local aging and adult services.
  • Distinguish roles and responsibilities for APS, IHSS, PA/PG/PC, AAAs, and ADRCs.
  • Explain cross-agency compliance mechanisms with CDSS, DHCS, CDA, DDS, DOR, and CalHHS.
  • Evaluate alignment opportunities and challenges with the Master Plan for Aging (MPA) and Master Plan for Developmental Services (MPDS).

Key Content:

  • AAAs compliance snapshot: OAA/OCA alignment; CDA oversight; Area Plan requirements; Title 22 operations; equity targeting; CARS data reporting; civil rights compliance; monitoring and audits.
  • APS compliance snapshot: WIC §§ 15750–15766; MPP Division 33; mandated reporting; timelines; confidentiality; cross-reporting; civil rights compliance; SOC 242 monthly reporting; NAMRS alignment.
  • IHSS compliance snapshot: WIC §§ 12300–12330; MPP Division 30; Medi-Cal standards; EVV; QA/QI; fraud prevention; CMIPS II statewide system; NOA and service authorization rules.
  • PA/PG/PC compliance snapshot: Probate Code and WIC; court oversight; due process; CAPAPGPC certification; least restrictive alternatives; interagency coordination.
  • Civil Rights (Division 21): Title VI, Section 504, ADA Title II; language access; reasonable accommodations; civil rights plans; PUB 13 and PUB 470.
  • Strategic alignment: Integrate local practices with MPA/MPDS; strengthen cross-system partnerships (e.g., courts, Regional Centers, Independent Living Centers, Public Authority, housing programs).

Activities:

  • Map compliance: Create a one-page compliance matrix for AAA, APS, IHSS, and PA/PG/PC (codes, manuals, reporting, civil rights).
  • Document flow: Diagram local workflows for mandated reporting, service authorization, and court petitions.
  • Equity check: Review civil rights plans and language access protocols; identify gaps and quick wins.
  • Data readiness: Confirm local APS SOC 242 and IHSS CMIPS II reporting cadence, owners, and quality controls.

Coaching Session:

  • Structure review: Walk through org chart; clarify program scope, stakeholder roles, and champions.
  • Reflection: Communication strategies across teams; skill needs; action steps; timetable.
  • Wrap-up: Strengths, worries, next steps; identify capacity-building strategies and bench strength.

Segment 4: Program overviews, data reporting training, and professional organizations

Learning Objective:

  • Understand AAA, APS, IHSS, and PA/PG/PC program overviews and reporting.
  • Strengthen data literacy for CARS, OAAPS, SOC 242, CMIPS II, QA/QI, and Program Integrity.
  • Leverage statewide associations to support compliance and practice improvement.

Key Content:

  • AAA & CDA data: Area Plans (4-year + annual updates); quarterly CARS submissions; OAAPS state reporting; enforcement tools (conditional approvals, CAPs, funding withholds, audits).
  • APS operations: Eligibility/jurisdiction; response timelines; investigation and findings; records and retention; cross-reporting; confidentiality; SOC 242 monthly reporting; dashboard use.
  • IHSS operations: Eligibility and application timelines; assessments/reassessments; FI/HTGs; NOAs; provider enrollment and exclusions; overtime rules; ESP/TTS; QA/QI thresholds; Program Integrity (SOC 824, 2245, 2248).
  • PA/PG/PC operations: Probate and LPS conservatorship pathways; evidence standards; estate administration; indigent burials; local data realities and court reporting; compliance risks and sanctions.
  • Professional bodies: CWDA (Adults Committee, PSOC, LTCOPS); C4A; CAPAPGPC; NAPSA; training academies (APSWI, ASTA/CSU Fresno, UC Davis); IHSS Training Academy.

Activities:

  • Data drills:
    • AAA: Pull CARS data; compare to Area Plan priorities and equity targets.
    • APS: Review SOC 242 trends; confirm definitions and intake coding.
    • IHSS: Assess QA/QI and Program Integrity reporting; meet with QA/PI leads.
    • PA/PG/PC: Engage County Counsel; observe court; assess reports to BOS.
  • Association engagement: Identify committees to attend; set a calendar; prepare agendas and questions.

Coaching Session:

  • Comparative oversight: Discuss differences in state oversight (AAA vs APS/IHSS vs PA/PG/PC).
  • Reflection: New compliance challenges; data/reporting readiness; stakeholder engagement.
  • Wrap-up: Actions to strengthen reporting, transparency, and partnerships.

Segment 5: ACLs, ACINs, ACWDLs, and CFLs

Learning Objective:

  • Learn how to access and implement state policy letters and fiscal notices for compliance.
  • Differentiate letter types and integrate guidance into local workflows and training.

Key Content:

  • Letter types:
    • ACLs: Formal directives—new policy, implementation requirements.
    • ACINs: Information, clarifications, best practices, timelines.
    • ACWDLs: Technical, health-related (e.g., Medi-Cal), fiscal coordination.
    • CFLs: Fiscal operations—allocations, claiming, methodologies, controls.
  • Access and organization: CDSS Letters and Notices portal; organize by year and program; track status and accountable owners.
  • Operationalization: Translate into local policies/SOPs, staff training, QA/QI checks, and fiscal practices; align with monitoring tools and dashboards.

Activities:

  • Policy pipeline: Build a “Letters & Notices Tracker” with fields for type, program, summary, required actions, owner, due date, and status.
  • Fiscal sync: Crosswalk CFLs with budget timelines, claiming procedures, and allocations.

Coaching Session:

  • Review set: Walk through a curated set of recent ACLs/ACINs/ACWDLs/CFLs.
  • Pros/cons: Compare clarity, timeliness, and impact across programs; identify friction points.
  • Wrap-up: Define a sustainable policy-implementation workflow and escalation paths.