Ugh. Well, some services yes, some no, some wait 60 days. Finally, the CCS program is going to do a one-year trial and will not require a “place of fixed habitation” to be able to get case management and substance abuse services.Here’s a memo (CCS Residency Memo 1-8-20 (002)) that shines the most light that I have ever seen on this issue! Every time we brought this up they said it was a state regulation that prevented the county from providing CCS services to homeless individuals. I see they found a way around it! Kudos to whomever finally broke through this log jam!!! Many have tried . . .
WHAT IS CCS?
From the Dane County Website – note, it doesn’t say you can’t apply if you are homeless, but we’ve all known that to be true for years:
Comprehensive Community Services (CCS)
General Information
View the CCS Brochure in English, Hmong or in Spanish.
In Dane County, Comprehensive Community Services (CCS) is a voluntary, community-based program funded by the State of Wisconsin and operated by the Dane County Department of Human Services.
The CCS program offers a wide array of psychosocial rehabilitation services. These are services and supportive activities that assist CCS clients with mental health and/or substance use conditions to achieve their highest possible level of independent functioning, stability, and independence, and to facilitate recovery.
The CCS program can provide a number of services needed at no cost to the client. Services that fall under the Service Array and are part of the client’s approved Recovery Plan are fully covered. The CCS Service Array includes the following areas:
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- Screening and Assessment
- Service Planning
- Service Facilitation
- Diagnostic Evaluations
- Medication Monitoring
- Physical Health Monitoring
- Peer Support
- Individual Skill Development and Enhancement
- Employment-Related Skill Training
- Individual and/or Family Psychoeducation
- Wellness Management and Recovery/Recovery Support Services
- Psychotherapy
- Substance Abuse Treatment
Basic eligibility criteria includes:
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- Dane County resident;
- Eligible for Medical Assistance;
- Have a mental health or substance use diagnosis;
- Functional limitation in one or more major life activities caused by mental health or substance use issues as measured by the state screen;
- Need for psychosocial rehabilitation services;
- Must have a current physician prescription for services.
WHY COULDN’T HOMELESS PEOPLE GET CCS SERVICES?
Seems like a no-brainer, right? Wouldn’t these services help folks become not homeless?
Well, the memo CCS Residency Memo 1-8-20 (002) explains in part:
The Wisconsin Department of Health Services and its predecessors have issued several policy memos that have clarified county residency for purposes of service provision in Wisconsin. A residency manual that is attached to a Numbered Memo (DDES 2007-01) establishes the criteria that a person must meet in order to be considered the resident of a county. Because counties have a statutory obligation (Chapters 46, 51, and 55) to serve their residents within available resources, it is necessary to define who is a resident of a particular county for these purposes. To that end, DOES 2007-01 outlines four criteria that must be simultaneously met to determine whether a person is a resident of a particular county:
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- Physical presence within the county
- Physical presence is voluntary (per the individual or by the choice of their legal guardian)
- The individual has the intent to remain in the county
- The individual is in a place of fixed habitation within the
Where questions arise about a person’s residency, it is most often related to the fourth criteria: whether a person is in a place of fixed habitation within the county. The residency manual attached to ODES 2007-01 clarifies what is meant by this phrase:
Examples of a place of fixed habitation include a home, apartment, condominium, residential hotel or a mobile home (fixed on a site). It also may include a nursing home, CBRF or other supervised residential facility when the person intends to live there for the foreseeable future because he or she has long term care needs and the services of the facility are needed to meet those needs. A motel, hotel (except a residential hotel), or rooming house are generally not considered places of fixed habitation, However, in limited situations a motel, hotel or rooming house may be considered a place of fixed habitation if the person lives there voluntarily and intends to remain there for the foreseeable future.
A place of fixed habitation does not include a car or other motorized vehicle because it is not a fixed habitation. Nor does it include an emergency shelter for the homeless because it is by definition a temporary shelter, a shelter for victims of domestic abuse, or a nursing home, CBRF or other supervised residential facility where a person’s stay is temporary to address acute care needs.
This fourth criteria is sometimes seen as a barrier to individuals who need access to certain behavioral health services, particularly those homeless individuals in our county. Currently, individuals in this situation are referred to services in the county where they last had a place of fixed habitation. If the person is a Medicaid beneficiary they may be referred to covered behavioral health services such as outpatient care and psychiatry. If a person is in need of additional support of the kind that the Comprehensive Community Services (CCS) Program offers, people who do not meet that fourth criterion will be referred back to the CCS program in their home county. Returning to the home county to obtain these services may not be a feasible option for many who are currently homeless.
This is interesting, what if the last fixed place of residency was in Dane County – seems like the county was still denying people. Fascinating.
WHAT IS THE NEW PILOT PROGRAM?
This is huge for those who have tried to get help and couldn’t. There still will be a mountain of obstacles, particularly if people are homeless, but one barrier is not removed.
In an effort to help as many people into recovery as we can, the Dane County Comprehensive Community Services (CCS) Program will pilot an exception to this residency criteria for one year. Effective January 13, 2020, when determining Dane County residency for the CCS program, an individual must meet the first three of the four criteria of residency as delineated in DOES 2007-01 (physical presence, voluntary presence, intent to remain in Dane County). If an individual is not simultaneously in a place of fixed habitation within Dane County, the individual may be considered as having met the fourth criterion through the demonstration of 60 days of consistent engagement with homeless-related services. This engagement can be verified by service provider entries in the Homeless Management Information System (HMIS). Sixty days of engagement may also be demonstrated by documentation from a homeless service provider on agency letterhead that indicates the person’s name, date of the person’s first contact with the agency, and a statement of the agency’s consistent involvement with the person since that first contact.
This pilot will apply to the Dane County CCS Program only. All other services will determine county of residency consistent with state and Dane County policy. At the end of this pilot period, the CCS Program will report on the following: the number of persons screened for whom this exception was applied; the number of resulting program admissions;· the average length of stay in the program for this group of admissions compared to all program admissions; and the percent of these admissions who obtained stable housing while in CCS.
The Dane County Department of Human Services strives to support all of its residents. We recognize that there are some in our community who are working toward, but have not yet gained stable housing, This pilot will help assure that this circumstance does not prevent access to a needed level of behavioral health services in Dane County.
Well, support all its residents, after 60 days of homelessness and you prove you will work with a homeless service agency.
HOW ASS BACKWARDS IS THIS?
Dane County values, eh? Stay homeless for 60 days and then we’ll help you when you only have 30 days left in shelter . . . and create so much paperwork that by the time you get through all the screening and process you’ve been homeless 3-6 months and have run out of shelter time.
Housing First is the idea that you put people in housing, then you work on the various services that you need. That is a lofty goal that we have, but we don’t have near the resources that are needed to make that happen for more than a handful of people.
The opposite of Housing First is making people be “ready” for housing before they get into housing.
Here in Dane County, we have no to very little Housing First and we won’t allow you access to services to become “housing ready” to get into non-Housing First housing.
Yup. Dane County values.
Seriously, how do we have policies that prevent people from accessing services because they are homeless. Shouldn’t the people who are homeless be one of the top priorities. It would be so much cheaper to provide services and give them housing than to maintain our messed of “homeless services system” that is trying the best they can with so little.
Dane. County. values.
Isn’t the purpose of these requirements to ensure that Dane County resources are used to benefit Dane County residents? Do you think Dane County should take on the burden of caring for homeless people from all over the State and Country? Doesn’t that mean fewer resources for our own residents? How does a homeless person prove they are a resident? If a homeless person moves here from Chicago and lives with a friend or relative for 60 days, should they qualify for homeless benefits here? Should t we be focused on maximizing the benefits to our own homeless residents? Wouldn’t a one or two year residency requirement be more effective in discouraging homeless people from other communities from coming here and taking advantage of our limited resources?
There are hundreds of people who are “chronically homeless” by HUDs definition – homeless longer than a year or homeless 4 times in three years – right here in Dane County. Those folks can’t access Dane County Human Services because of these rules. If you’re chronically homeless, you shouldn’t have to jump through hoops to get services.
Also, youth aging out of the foster care system who suddenly have no place to live – they shouldn’t be eligible for services because they have no fixed place of residence?
A mom who just had a baby and just got out of the hospital? They shouldn’t be eligible?
I don’t think we have a massive run on people flocking to Madison because of our Cadillac services for people without homes . . . quite the opposite. If people are looking for a place to go – they’d go south or west (warmer) or Minnesota (better services)