10: Business Skills for Independent Facilitators

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What we will learn

"Other duties as assigned" - the work you didn't know you were signing up for as an IF
Create a list of services you will provide as an independent facilitator
Explore software you can use to keep your business organized

What IFs do, besides helping people in SDP

This whole chapter is about what IFs do, so I wrote it as a conversation with you. I work as an independent facilitator, too, so telling you about it from my perspective makes more sense to me.

Time Management and Organizational Skills for Effective Project Management

Business management includes taking care of your business finances, operations, and client development. If serving as an independent facilitator is your full-time job, these tasks could become an overwhelmingly large part of your professional responsibilities. As you grow your business, these tasks will grow.

Visual aids and checklists help participants understand where you are in the SDP process. Monthly assignments or to-do lists can help your clients stay organized and take on increasing responsibility for the work of SDP. Consider creating an organizational tool to keep clients organized. Create one for yourself first. This will help you understand what parts of the program have business skills that you may not yet have.

You are brilliant. You can learn new things. And you can do hard things.

Conflict Avoidance and Resolution

As discussed before, communication skills are a large part of success as an independent facilitator. Clear communication and timely responses to questions can help your clients thrive in SDP.

Operations

Consider how your regional center goes through the process of moving someone into the Self Determination Program. Locate the regional center's SDP process on their website. If you can't find it, send a note to the SDP email and the participant-choice specialist listed on the SDP page of the regional center website. If your regional center no longer has participant-choice specialists, attend the local volunteer advisory committee (LVAC) or send their chair an email asking for the process. Do not give up. The process should be available and transparent.

It can be difficult to plan operations around the operations of others, but that is the key to making SDP work for real people.

What technology could help you make the process easier?
What skills do you need to develop in order to serve your clients well?
What are the hardest stages of the SDP process at the regional center you are working with?
What can be done to advocate for improvements in that stage of the SDP process?

Client Development

After you have supported your first client in SDP, take the time to reflect on what went well and what you would like to do differently in the future. Once you have reflected on the process, create a plan to improve your process.

Another important consideration is to match clients and IFs with similar goals, personalities, and ethics. If a prospective client approaches you wanting to switch from their original IF, it may be wise to ask more about the situation. Sometimes, the previous IF was unresponsive, overcommitted, or struggled to manage challenges with a regional center effectively. However, there are also times when a client is asking for support to do something that is unethical, illegal, or unwise. If you are uncomfortable with the way a person is trying to use Medicaid-funded services, be clear with them. Do not agree to support someone who is doing something you know is unethical or illegal.

There are various ways to express yourself clearly.
Here are some possible template language for different challenges:

Unallowable expenses

“What you are suggesting is not in line with the Medicaid regulations that govern this program. I do not recommend trying to break the law.”

“I don’t think I am a good fit for your current goals.”

“There may be other resources to fund ____________. Have you asked your service coordinator if she knows any non-profit organizations or community resources that help with that? Unfortunately, what you are hoping to do is not allowed in SDP.”

Questionable rates

“I noticed that you want to pay three staff members (Community Living Coaches) $26/hour and one of them $75/hour. That is a big difference for the same job. Let's make sure there is a reasonable justification for the discrepancy.”

There are ways to avoid this from happening. It makes sense to talk with the participant early to explain your philosophy and comfort level with questionable creativity. If the justification for the wildly different hourly rates is that the participant wants to pay a family member more money than non-family members, that feels a little icky, right? If the reason is the $75/hour staff has different job expectations and responsibilities, then it is a different job and it needs a different job title and description. Consider including job descriptions for both staff roles when submitting the spending plan in anticipation of the question. Acknowledge that there is a vast difference and explain it.

In short, do not pay people with similiar skills and experience vastly different wages for exactly the same work.

This program needs every single independent facilitator working to improve this program’s sustainability. We all do better when we all do better. We can support each other and still hold ourselves to high standards. We can lead by example and maintain strong professional reputations as a community.

Honesty, openness, and clear communication matter deeply. Make sure you are honest about how you plan to support the client, and be honest about what you are not willing to do.

Keeping Organized SDP Participant Records

Naming conventions

Folders by participant

Managing workload

This program can be a lot of work. Consider completing the process with one complete client before adding more. Start with the PCP, move to pre-transition supports, and move them into year 1 of SDP before trying to grow your business. If you can find a mentor, work with an experienced independent facilitator you trust.

Once you are comfortable working with your chosen regional center, adding new clients can be a wonderful experience.

Participant Privacy

Sharing personal information about clients is not acceptable. Some of the information people share with you is protected by the Health Insurance Portability and Accountability Act of 1996 ("HIPAA").

The Department of Health and Human Services summarizes HIPAA and the associated privacy protections it provides like this:

A major goal of the Privacy Rule is to assure that individuals' health information is properly protected while allowing the flow of health information needed to provide and promote high quality health care and to protect the public's health and well being. The Rule strikes a balance that permits important uses of information, while protecting the privacy of people who seek care and healing. Given that the health care marketplace is diverse, the Rule is designed to be flexible and comprehensive to cover the variety of uses and disclosures that need to be addressed.

It is important to know that protecting privacy and being a trustworthy partner is vital in this field. While medical information is HIPAA protected, non-medical information is still private. Do not share personal information about your clients. Always use a Release of Information (ROI) document. Immediately share the release with the regional center when you introduce yourself as the client’s independent facilitator.

Professional Responsibilities

Program Updates and directives from the Department of Developmental Services occur regularly in this evolving program. As a result, on-going and regular professional development is needed to serve clients well.

Clear expectations from the start

When I start working with a new participant, I try to communicate openly. Below are tasks I am willing (and not willing) to complete as an independent facilitator.

What I do as your IF

Help create a vision for what life with SDP supports could look like
Troubleshoot challenges with RC and FMS
Support client with RC or FMS when there is an impasse
Create template email messages with necessary information to help solve problems
Help create a to-do list for the family/participant to complete
Brainstorm
Help create annual spending plans
Attend IPP at your request
Identify changes in circumstances and unmet needs on an on-going basis
Provide you with Excel and Word documents (or shared Google Drive files) of your spending plan and PCP – this way you can make your own adjustments as time goes on
Help you create job descriptions for positions you need to hire
Empower and train you to understand how SDP works so eventually you will be able to do this work without me.
Follow the rules of SDP

What you need to do as an SDP participant

Make the SDP vision a reality (or as close as possible)
Submit purchase requests connected to your spending plan (the IF should never be completing this task).
Recruit and hire staff for the positions you need
Review your monthly spending and ensure your records match your FMS’s records.
- When they don’t match, you need to contact them to fix the discrepancy
Contact potential services and supports to make sure they will work with your FMS
Connect potential service provider with your FMS
Ensure service providers understand how to get paid
Approve and submit invoices
Approve staff hours per FMS rules and systems
Create staff and activity schedule for and with your loved one
Ask me for help when you need it
Learn how this program works so you can decrease your need for me over time
Follow the rules of SDP
Other tasks, as they arise

Determining rates and billing

Like all professions, Independent Facilitators have different levels of professional experience and education. There are requirements in statute that mention needing training in person-centered practices, but this is not hands-on or practical experience. It is based on the desire for planners to understand person-centered thinking and how to apply that to the planning process for SDP.

The hourly rate you set should cover your costs – like income taxes – and provide income. Keep in mind that there are independent facilitators charging very high rates –between $300-$1000/hour — which complicates our profession with the regional centers and the Department. Please be mindful of that impact as you determine reasonable and appropriate rates for your services.

It is important that the rate charged matches the combination of the value you provide and a desire to maintain system sustainability. There are ways to charge rates that reflect your growth as a professional, your expertise, and your education levels.

How people determine their hourly rate can be a difficult as an independent facilitator. Typically hourly rates take into consideration levels of education, experience, and quality of work. Since independent facilitator services cannot add to funds through the budget process, charging a high hourly rate can be problematic and unsustainable for SDP participants. The only way for a participant to hire an IF is for them to make the choice to take away from funds in another area.

This service might provide a participant with a form a respite -- the rest comes from not having additional stress and responsibility to learn all aspects of SDP in a short amount of time. So instead of using all of the respite hours as in-home respite in the traditional system's sense, the respite is a relief of responsibility while supporting the family to maintain the person-served in their natural environment.

Consider the tasks an IF has to complete, the on-going learning and training that has to be current, and the responsiblity and risk of the job. Because 1099 consultants are responsible for all aspects and costs of their work, the hourly wage may sound higher than it actually is. Remember 25-30% of the hourly rate will likely go to taxes, Medicare and Social Security contributions, and hopefully retirement savings, the rate needs to consider those responsibilities.

Rates may also reflect professional experience, education, and value of service.

IF 1: The newbie

Completed an IF Training
Has an IF mentor provided by LVAC funding
Wants to grow a business
Has business experience, but is new to disability services
Has an associate's degree
Still learning the ins and outs of their local processes
Wants to do a good job, but recognizes they have a lot to learn to be more effective and efficient
Has helped one person in a volunteer capacity to enter the program

Perhaps this person should consider starting with a lower hourly rate to start with the person-centered plan -- the cap on the PCP using service code 024 is $1000. Keep a log to track the hours.

Since the Pre-transition Enrollment supports rate is set by the Department of Developmental Services. Each regional center has an approved hourly rate. All are around $50/hour.

Maybe this IF starts their first client between $45-65/hour and communicates that as they grow in competence, the rate will likely increase in year two.

IF 2: The Veteran

Has worked as an independent facilitator since the program began in 2020.
Has a master's degree
Has professional experience in interpersonal communication and teaching
Teaches multiple SDP classes
Has a stated philosophy of empowerment, increasing competence in participant and decreasing need for IF support over time

The person-centered plan and pre-enrollment supports rates are still set rates. No need to stress over those.

The hourly rate might be between $75-150/hour.

My personal philosophy on rates

I do not have monthly check ins or required monthly "subscriptions" for my clients.
I work alone (I do not have employees.)
I try to teach my clients how to solve their own questions, fix their own spending plans, document their own changes in circumstances, and so much more. This builds capacity in the people I serve.
I do not charge per text, per question, per minute. If I know the answer to a question and a response can be sent quickly to help a client solve their own problem, I just answer it. No charge, no problem, just good service.

How I plan for IF need in spending plan

This is just a typical regular need particpant. There are always people who need more and people who need less.

Year 1: 1 hour/month = 12 hours at $125/per
- total in spending plan = $1500
Year 2: 6-8 hours for the year
- total in spending plan ~$1000
Year 3+: We evaluate the changes and challenges happening at their regional center and plan accordingly.

Things I charge for:

Communication: email, text (if it's a longer chain of questions-- not one quick question), phone
Meetings (check-ins, Zoom with participant, Zoom with team/regional center/other)
Research (at participant's request)
Creating template emails (at participant's request)
Helping create a vision (at participant's request)
Calls with your FMS or regional center (at participant's request)
Anything in the list above or other supports you ask me to provide in SDP

Other models

Some people schedule monthly check-ins. Others schedule quarterly ones. Still others work for an IF agency which provides them connection, mentorship, and collaboration. If you are concerned about being able to budget or grow your business, come up with a fair and ethical way to bill.

Deciding what services you will offer

Set reasonable and clear expectations for both yourself and your client. Make sure they are aware of all the things you do and do not do. Also help them understand that even when you are not working directly for your client, there are many statewide meetings and independent facilitator groups that you may be attending. Keeping current with directives, changes in trailer bill language, and funding challenges takes a lot of time. That is one reason being thoughtful about how you set your hourly rate is important.

There is no reason a participant cannot hire multiple independent facilitators. The independent facilitators simply cannot be paid in any other area of the spending plan. If you are hoping to create a niche business, you can do that, if the client wants that type of service.

Services that DDS outlined in their December 21, 2018 directive

IFs can provide assistance in the following ways:

Assisting the individual with making informed decisions regarding their individual budget;
Locating, accessing and coordinating services and supports consistent with the participant’s Individual Program Plan (IPP);
Identifying immediate and long-term needs and developing options to meet those needs;
Leading, participating, and/or advocating on behalf of participants in the person-centered planning process and development of the IPP; and,
Obtaining identified services and supports.

However, just because the directive says an IF can provide these services does not mean that an IF provides all these services. Perhaps your expertise is in locating services in your community, and that is the one area you want to serve.

Remember, if you provide all of these services, consider making time to teach and empower those you serve to increasingly complete these tasks independently. Write into the spending plan a life coach who can practice finding services in the community for the person-served to develop these skills, too.

Deeper thinking about what IFs really do

Create a list of SDP-related tasks you feel comfortable providing today. Then, create a list of skills or tasks you want to develop further. What is missing from the lists above? Get ready for an online discussion on expectations.

Transition into Self Determination Program: Ways to be paid to support participants move into SDP

099

Definition (plain language)

099 Vendorization: Courtesy Vendorization

Vendored Payment Process

Pre-Enrollment Supports for Self-Determination Program (099-PDS)

099-PDS services help after your Person-Centered Plan is done and support your move into the Self-Determination Program. You choose who provides these supports—they don’t have to be vendored with your regional center. This is often done by an Independent Facilitator (IF).

Plan to do this at least 2 weeks before you want/hope/desire to start pre-transition support services

Step 1: Participant Chooses Independent Facilitator

Decide what kind of help you need and who you want to provide it.
You do not have to use regional center vendored providers—you can choose anyone qualified.

To qualify, a provider must:

Have experience with people with developmental disabilities (lived or paid experience—at least 1 year);
Complete a training about the SDP; and
Understand the Lanterman Act and SDP rules.

Step 2: Independent Facilitator Sends Info to Service Coordinator

The Independent Facilitator sends written details to the Service Coordinator, including:

What services they will provide (service options),
How many hours (up to 40), and
SC provides hourly rate (based on the consumer’s regional center rate).

Step 3: IPP Team and Service Coordinator Actions

The team agrees on the services, number of hours, and rate.
Service Coordinator updates the participant’s IPP to include the new service and participant signs addendum.
Service Coordinator requests Purchase of Service (POS) as two authorizations
- General SD Supports (service code 099, subcode “PDS”)
- Financial Management Service (FMS), Fiscal Agent (service code 490)
Service Coordinator will send Face Sheet to the Financial Management Service (FMS)
Service Coordinator will provide contact info for the FMS vendored for Participant-Directed Services (this FMS may differ from the one the participant chooses for their own SDP) to consumer and provider.

Step 4: Independent Facilitator Onboarding with FMS

The Independent Facilitator gives the FMS:

W-9 form
SDP General Supports Qualifications and Agreement Form*
HCBS Provider Agreement Form*
Business license (if required)**

* Per DDS Directive (July 2, 2024)

** Per Participant-Directed Services (PDS) waiver requirements

Step 5: What the FMS Does

Onboards Independent Facilitator confirming they are qualified
Works with the regional center to receive both POS authorizations (099 for IF and 490 for FMS)
Tells the Independent Facilitator the start date (services done prior to start date cannot be invoiced)
Pays the Independent Facilitator once the POS is active

Step 6: Invoicing

The participant approves hours invoiced by the Independent Facilitator:

The IF sends a monthly invoice (use template).

The participant or family must approve it using one of these methods:

Participant signs the invoice (digital or physical) and IF sends to FMS -or-
IF emails invoice to participant who forwards to the FMS stating hours are approved

Comparison of 099 and 099-PDS
	099	099-PDS
What it does	099 vendorization allows a pre enrollment professional to support an individual as they move from the traditional system into the Self Determination Program. Paid through the e-billing system.	Allows transition support without being a regional center vendor. You will be paid through FMS designated by the regional center.
How long it takes to complete the process	It depends on the regional center, but all of the requirements in the vendor packet must be met (typically min 30 days).
How to initiate the process	IF reaches out to their local regional center staff person in charge of vendorization.	Participant requests 099-PDS services with their service coordinator. The service is added to the IPP. The service coordinator will send referral to the FMS that provides 099-PDS. The team will agree on number of hours. The service coordinator will request purchase of service authorizations (both General SD Supports (099-PDS) and Fiscal Agent (code 490).
How many hours	Up to 40 hours (more can be provided by exception)	Up to 40 hours (more can be provided by exception)
Paperwork required	(outlined in the DDS directive)	W-9 form SDP General Supports Qualifications and Agreement Form* HCBS Provider Agreement Form* Business license (if required)
How to complete the process	Contact	The IF will register with the FMS.
Where you can work	Your vendorizing regional center, then as a courtesy vendor when the other regional center’s requirements are complete (additional insurance requirements are possible)	Only for the client that was approved for these hours.
What are the rates	Rate is set by DDS and is based on the participants regional center rate (not your vendor home regional center)	Rate is set by DDS and is based on the participants regional center rate (not your vendor home regional center)
Invoicing		The provider sends a monthly invoice (use template). The participant or family must approve it using one of these methods: Participant signs the invoice (digital or physical) and provider sends to FMS -or- Provider emails invoice to participant who forwards to the FMS stating hours are approved

Person-Centered Plan Payment Process (024)

024 vendor number needed to charge to

Billing FMS

There are invoice requirements in the Self Determination Program. When billing, make sure to follow the current rules. Not doing so may create an unnecessary delay in payments.

Invoicing and Billing

Getting Started with a new participant

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What I do as your IF

What you need to do as an SDP participant

How I plan for IF need in spending plan

Deeper thinking about what IFs really do

Comparison of 099 and 099-PDS