RSA-509 - Protection & Advocacy of Individual Rights (PAIR) Program Performance Report

Iowa (IOWA P and A SERVICES, INC.) - H240A170016 - FY2017

General Information

Designated Agency Identification

NameDisability Rights Iowa
Address400 East Court Avenue
Address Line 2Suite 300
CityDes Moines
StateIowa
Zip Code50309
E-mail Addressinfo@driowa.org
Website Addresshttp://www.driowa.org
Phone515-278-2502
TTY Relay 711
Toll-free Phone800-779-2502
Toll-free TTYRelay 711
Fax515-278-0539
Name of P&A Executive DirectorJane Hudson, Executive Director
Name of PAIR Director/CoordinatorCynthia A. Miller
Person to contact regarding reportCynthia A. Miller
Contact Person phone515-278-2502
Ext.32

Part I. Non-Case Services

A. Individual Information and Referral Services (I&R)

Multiple responses are not permitted.

1. Individuals receiving I&R within PAIR priority areas57
2. Individuals receiving I&R outside PAIR priority areas295
3. Total individuals receiving I&R (lines A1 + A2)352

B. Training Activities

1. Number of trainings presented by PAIR staff7
2. Number of individuals who attended training (approximate)380

FY17 PAIR PPR I-B The following are seven trainings conducted by staff that related to the PAIR program in FY 17: 1. ASK/AEA - ASK Resource Center (Parent Training and Information), the AEA’s and DRI have collaborated to develop training on the implementation of the Workforce Innovation Opportunity Act for students in school. This training is designed for parents, students and school staff. The training is available on all of the participants’ websites. 2. Alternatives to Guardianship Opportunity Village - DRI presented to staff, guardians, and parents of adults with ID and other disabilities about the rights of people under guardianship and other less restrictive alternative forms of substitute decision making. 3. Arizona P&A on monitoring — DRI trained staff at Arizona Center for Disability Law. Training included the following topics: Preparing for Monitoring, Activities on-site, Conditions, Abuse and Neglect, Discharge Planning, PASRR, Systemic Issues, Basic Interviewing Skills, Follow-up and Relations to Investigations. 4. Autism Employment Conference - DRI presented to people with autism and support professionals on the rights of employees with disabilities under the ADA, requesting reasonable accommodations, navigating employment with a disability, and how to handle possible discrimination in the workplace. 5. Four Plus program — DRI trained local education agencies, parent advocacy agencies, and Four Plus program providers to further clarify for schools and 4 plus programs the implementation of student eligibility for services under the IDEA when they have completed their local districts’ graduation requirements. 6. ISBA conference on Managed Care Appeals and Grievances — DRI presented to attorneys and judges on the federal and Iowa statutes and regulations on how to file for grievances and appeals in the Medicaid managed care system. 7. Training U of I on ADA and DRI services — DRI provided training to Social Work students on the nature of the Americans with Disabilities Act, its various provisions, and the nature of DRI's work, to increase their proficiency in the area of disability rights.

C. Information Disseminated to the Public

1. Radio and TV appearances by PAIR staff4
2. Newspaper/magazine/journal articles11
3. PSAs/videos aired0
4. Hits on the PAIR/P&A website13,231
5. Publications/booklets/brochures disseminated512
6. Other (specify separately)4

Narrative

DRI disseminated information via powerpoint to a group of parents and guardians of adults with disabilities. DRI disseminated information via classroom and individual instruction to a group of recent refugees from Eastern Africa. DRI disseminated business cards to individuals while conducting a monitoring at a state correctional facility. DRI disseminated information via a remote web-based training on monitoring to Arizona P&A staff.

Part II. Individuals Served

A. Individuals Served

Count individual once per FY. Multiple counts not permitted for lines A1 through A3.

1. Individuals still served as of October 1 (carryover from prior FY)11
2. Additional individuals served during the year38
3. Total individuals served (lines A1 + A2)49
4. Individuals w. more than 1 case opened/closed during the FY. (Do not add this number to total on line A3 above.)1

B. Individuals served as of September 30

Carryover to next FY may not exceed total on line II. A.3 above 12

C. Problem Areas/Complaints of Individuals Served

1. Architectural accessibility9
2. Employment6
3. Program access6
4. Housing4
5. Government benefits/services5
6. Transportation0
7. Education0
8. Assistive technology3
9. Voting0
10. Health care10
11. Insurance0
12. Non-government services1
13. Privacy rights1
14. Access to records0
15. Abuse4
16. Neglect0
17. Other1

D. Reasons for Closing Individual Case Files

1. Issues resolved partially or completely in individual favor27
2. Other representation found0
3. Individual withdrew complaint7
4. Appeals unsuccessful0
5. PAIR Services not needed due to individual's death, relocation etc.1
6. PAIR withdrew from case1
7. PAIR unable to take case because of lack of resources0
8. Individual case lacks legal merit2
9. Other0

Please explain

E. Intervention Strategies Used in Serving Individuals

List the highest level of intervention used by PAIR prior to closing each case file.

1. Technical assistance in self-advocacy3
2. Short-term assistance12
3. Investigation/monitoring4
4. Negotiation10
5. Mediation/alternative dispute resolution0
6. Administrative hearings5
7. Litigation (including class actions)3
8. Systemic/policy activities1

Part III. Statistical Information on Individuals Served

A. Age of Individuals Served as of October 1

Multiple responses not permitted.

1. 0 - 40
2. 5 - 221
3. 23 - 5934
4. 60 - 645
5. 65 and over9

B. Gender of Individuals Served

Multiple responses not permitted.

1. Females26
2. Males23

C. Race/Ethnicity of Individuals Served

For individuals who are non-Hispanic/Latino only

1. Hispanic/Latino of any race0
2. American Indian or Alaskan Native0
3. Asian1
4. Black or African American3
5. Native Hawaiian or Other Pacific Islander0
6. White45
7. Two or more races0
8. Race/ethnicity unknown0

D. Living Arrangements of Individuals Served

Multiple responses not permitted.

1. Independent41
2. Parental or other family home1
3. Community residential home1
4. Foster care0
5. Nursing home2
6. Public institutional living arrangement0
7. Private institutional living arrangement0
8. Jail/prison/detention center3
9. Homeless0
10. Other living arrangements1
11. Living arrangements not known0

E. Primary Disability of Individuals Served

Identify the individual's primary disability, namely the one directly related to the issues/complaints

1. Blind/visual impairment3
2. Deaf/hard of hearing5
3. Deaf-blind0
4. Orthopedic impairment20
5. Mental illness0
6. Substance abuse0
7. Mental retardation0
8. Learning disability0
9. Neurological impairment5
10. Respiratory impairment1
11. Heart/other circulatory impairment1
12. Muscular/skeletal impairment4
13. Speech impairment0
14. AIDS/HIV0
15. Traumatic brain injury4
16. Other disability6

Part IV. Systemic Activities and Litigation

A. Systemic Activities

1. Number of policies/practices changed as a result of non-litigation systemic activities4

2. Number of individuals potentially impacted by policy changes39,000

Describe your systemic activities. Be sure to include information about the policies that were changed and how these changes benefit individuals with disabilities. Include case examples of how your systemic activities impacted individuals served.

Systemic Transportation Project (Policy change) — DRI worked with local transit authority to address concerns that their hours did not mirror those of the fixed route system as required by federal regulations. Transit authority personnel worked with DRI advocate beyond the initial meeting to identify lingering issues beyond the time concerns, and these conversations resulted in DRI’s advocate being appointed to the Transit Advisory Council so he can play a more formal role in identifying and addressing issues. The transit authority also changed their policies to ensure paratransit mirrors the fixed route system to bring it into compliance with federal law. Special Education Advisory Panel — DRI participated as a member of this panel. The panel is tasked with functions and duties as specified by law, including offering advice, consultation, and recommendations to the Iowa Department of Education regarding matters concerning special education services. The panel worked to come up with strategies to close the achievement gap of students with disabilities. Scott County Park Accessibility Issues — DRI is working with local advocates in Scott County Iowa to address the accessibility of parking lots, bathroom, and cabins in local public parks. DRI has conducted reviews of affected facilities and drafted demand letters to appropriate governing bodies. This project is ongoing. Managed Care Iowa — DRI is working to assist Medicaid members affected by the transition to managed care, and ongoing changes to the system. DRI joined with the office of the Managed Care ombudsman to write and publish a guide for Medicaid members on how to self-advocate and file appeals and grievances under managed care. Accessibility of Caucus Sites (policy change) — Iowa is the first state in the nation to hold presidential preference caucuses. These caucuses are inaccessible to some individuals with disabilities because they occur only for two hours during the evening and do not provide reasonable accommodations. DRI met with representatives from both major political parties to discuss how to make their caucus sites accessible. DRI also spoke at several town halls about accessibility issues. After meeting with DRI’s director, the democratic party’s Caucus Review Committee indicated they would put our recommendations for improving accessibility in their final report to the party leadership. The adoption of these recommendations will increase access to the caucuses for people with disabilities. (Note, In FY18, the National Democratic Party recommended that the Iowa caucus have absentee balloting. DRI will report on this in its FY18 PPR). ILAST Coordinated Community Response to Elder Abuse — A grant was awarded to Iowa by the Office on Violence Against Women, U.S. Department of Justice to address elder abuse. The Iowa Attorney General's office is leading the effort with other partners in their grant team and DRI is participating as part of the Coordinated Community Response (CCR). The CCR is a multifaceted coordinated effort to address elder abuse by evaluating how systems work in order to enhance victim safety and hold offenders accountable. This project is ongoing. Systemic Prison Reform — DRI participated in a collaboration with organizations involved in prison reform issues, including the Board of Corrections, Friends of Iowa Women Prisoner's and other advocacy groups. DRI staff attended meetings organized by the Iowa Therapeutic Alternatives to Incarceration (ITAIC) group, as well as the Iowa Board of Corrections, and networked with attendees of other advocacy group and provider representatives including Friends of Iowa Women Prisoners (FWIP) and the Office of the Ombudsman. Commission of persons with Disabilities - A DRI staff member sits on this commission. The Commission discussed issues at their quarterly meetings during the past year concerning employment of persons with disabilities, mental health care in Iowa, managed care organizations and the impact on individuals with disabilities, and voting accessibility. The Commission joined the Department of Human Services’ legislative breakfast to educate lawmakers about the Commission, promote the commission, and increase the Commission’s visibility. One board member is involved in a job coaching program which coaches students with disabilities in resume writing and mock interviewing at the high school level. Another board member was instrumental in starting a Veterans’ Center in eastern Iowa five months ago and is already serving over 100 veterans and their families weekly, providing an array of services including haircuts, clothing for job interviews, meals, and counseling. Systemic County Jails — DRI monitored 30 county jails and completed a thorough systemic investigation of the housing and treatment of inmates with mental illness and disabilities in those settings. DRI published a comprehensive public report detailing our findings and recommendations and presented the information to Sheriffs, Boards of Supervisors, MHDS Regions and other stakeholders to effect discussions and promote change. Elder Justice Task Force — Along with the Department of Inspections and Appeals and Long Term Care Ombudsman, DRI participated in the task force with the US Attorney's Office of the Northern District to address elder abuse and substandard care. The US Attorney's Office has been active in pursuing substandard care and financial abuse and has updated the partners in its efforts. DOC incident reports — DRI reviewed incident reports on inmates with disabilities who reside at Iowa Department of Corrections facilities, monitored these reports for trends, patterns, abuse and suicides, with intent of investigating any egregious incidents or suicides if warranted. Guardianship and Conservatorship Task Force (policy change) — DRI participates in a work group of attorneys, judges, and professors that was established by the Iowa Supreme Court to review and make recommendations for guardianship and conservatorship reform in Iowa. The group has authored and submitted its report to the Supreme Court. In turn, the Supreme Court has proposed adoption of a probate rule that will prohibit judges from waiving the annual reporting requirement in guardianships and conservatorships. This project is ongoing and is expected to lead to necessary reform in the coming years. Enforcement of ADA in small cities — In conjunction with an investigator from the U.S. Attorney’s office, DRI is conducting a review of public buildings and facilities in small towns in Iowa. The purpose of the project is to identify barriers to access, notify the local governments in question, and work with them to resolve these barriers. Sexual Expression in Long Term Care — DRI collaborated in a multiyear project with Department of Inspections and Appeals and Long Term Care Ombudsman to develop a booklet titled "Sexual Expression Policy Development, A Guide for Long-Term Care Facilities & Assisted Living Programs". We also drafted sample resident/tenant sexual expression policy and a sample Facility's Resident and Tenant policy. In FY17 we received the final published document and used the document in DRI's monitorings of long term care facilities. Implementation of HCBS - DRI monitored six different providers of HCBS services in order to evaluate compliance with CMS's home and community-based settings rule and take appropriate action to ensure compliance with the rule as necessary. DRI found all six provider agencies to be generally in compliance or in the process of implementing changes to policy that would bring them into compliance. On May 9, 2017, CMS issued an Informational Bulletin to the states to extend the transition time period for full compliance by three years to March 17, 2022. Systemic State Fair Project: (policy change) DRI completed a multiyear project to have the Iowa State Fair board conduct a self-evaluation and adopt a transition plan for bringing buildings on the fairgrounds into compliance with the ADA. In FY17, the board finalized the self-evaluation and transition plan, published it, and delivered a copy to DRI. The execution of this plan will increase access at the fairgrounds to individuals with disabilities.

B. Litigation/Class Actions

1. Number of individuals potentially impacted by changes as a result of PAIR litigation/class action efforts15,742
2. Number of individuals named in class actions6

Describe your litigation/class action activities. Explain how individuals with disabilities benefited from your litigation activities. Be sure to include case examples that demonstrate the impact of your litigation.

DRI, in conjunction with co-counsel, filed a class action on behalf of Iowa Medicaid beneficiaries with intellectual disabilities, physical disabilities, and brain injuries who receive home and community based services from one of three waiver programs. By way of background, Iowa transitioned last year from a state run Medicaid program to a private, for-profit managed care plans. Initially the plans maintained some of the services for members with severe disabilities who need extensive home and community-based services to be able to live integrated into their communities and having access to community life similar to non-disabled individuals. However, the managed care companies claimed they were losing too much money on Medicaid contracts and began cutting members’ necessary home and community-based services without any significant changes to their health needs, neither giving them notice nor an opportunity to appeal. The class action was filed against the Governor and the Director of Department of Human Services in their official capacities (however, the Governor was later dismissed). Plaintiffs sought declaratory and both preliminary and permanent injunctive relief to halt the terminations and reductions of home and community-based services by Defendants and their agents until there is compliance with the requirements of the Medicaid Act, the U.S. Constitution, Iowa Constitution, the Americans with Disabilities Act and Section 504 of the Rehabilitation Act. Plaintiffs also petitioned for class certification. DRI represents plaintiffs along with co-counsel from the National Health Law Project and Roxanne Conlin & Associates, P.C. DRI also represented individuals in litigation under PAIR. On behalf of a client with paraplegia, we filed a federal lawsuit under ADA Title III against a local concert venue and event center that had no accessible restrooms. We obtained a default judgment and order for fees, and are seeking enforcement of the judgment which will make the venue accessible to people with disabilities. We also represented a client with a brain injury in a successful action to terminate his guardianship and conservatorship that were held by his estranged wife.

Part V. PAIR'S Priorities and Objectives

A. Priorities and Objectives for the Fiscal Year Covered by this Report

For each of your PAIR program priorities for the fiscal year covered by this report, please:

  1. Identify and describe priority.
  2. Identify the need, issue or barrier addressed by this priority.
  3. Identify and describe indicators PAIR used to determine successful outcome of activities pursued under this priority.
  4. Explain whether pursuing this priority involved collaborative efforts by other entities. If so, describe this collaboration.
  5. Provide the number of cases handled under the priority. Indicate how many of these, if any, were class actions.
  6. Provide at least one case summary that demonstrates the impact of the priority.

Abuse and Neglect: 1. Priority: Keep Iowans with Disabilities Safe 2. Need Addressed: Working to reduce abuse and neglect in facilities, by investigating and monitoring is a core function of Disability Rights Iowa. Abuse and neglect is any act or failure to act, by a person with a duty to care for an individual with a disability in a facility or service setting, which caused or may have caused an injury or death. Facilities and service settings are locations where individuals with disabilities receive services such as treatment, programming, or residential supports. 3. Description of activities: DRI will conduct individual investigations into suspected abuse or neglect, including deaths and injuries of individuals with disabilities resulting from abuse or neglect in institutional and HCBS settings. DRI will monitor facilities or service settings with allegations of abuse or neglect, with histories of the same, or as a matter of routine course. DRI will provide rights trainings to individuals residing at the mental health institutes and a self-advocacy training to individuals with mental illness. DRI will provide individual advocacy including technical assistance, negotiation, or other assistance, to protect the rights of individuals with disabilities receiving services in facilities or service settings. DRI will provide individual representation including injunctive or administrative interventions. DRI will collaborate with the Department of Inspections and Appeals, the Long-Term Care Ombudsman and others to prevent abuse or neglect. DRI will work to improve the investigations of other enforcement and oversight agencies when they are inadequate, and issue public reports, where appropriate, to create systemic change. 4. Collaboration: See description of collaboration with Long-Term Care Ombudsman in Section VI. DRI completed a multi-year project with LTCO regarding sexual expression in long-term care settings and used a publication authored during that collaboration when conducting monitorings. DRI also reviews incident reports from DIA or Department of Corrections for patterns of abuse and neglect and will conduct follow-up investigations as necessary. DRI is also collaborating with LTCO, Iowa DHS, Iowa Attorney General, County Attorneys, Law enforcement, and Iowa Coalition Against Domestic Violence as part of the Coordinated Community Response to address elder abuse and evaluate how systems work to enhance victim safety and hold offenders accountable. 5. Number of cases: 1 Number of class actions: 0 6. Case summary: DRI had one abuse case that carried over from the prior year. The client was a 60 year old man with progressive aphasia and dementia. A media report stated he was living in a local hospital as a result of no provider being willing to accept him for treatment. He was reported as having been restrained to his bed for months due to behaviors. DRI opened an investigation and obtained records via access authority. We interviewed a family member of the client and determined the hospital was meeting all requirements relating to restraint and the individual was receiving an appropriate level of care for his needs. DRI also conducted 11 monitorings of facilities and conducted a secondary death investigation of a resident’s death at one Iowa nursing facility. Accessibility: 1. Priority: Ensure Access to Services and Places 2. Need Addressed: Disability Rights Iowa remains committed to ensuring people with disabilities are given the opportunity to be full participants in every area of community life. However, we understand that opportunity in many cases is dependent on the availability of dependable and accessible transportation. Thousands of Iowans rely on accessible public and private transportation to meet their professional, personal, and recreational needs, and the capacity of those systems to meet demand are often woefully inadequate. Systemic deficits in both service coverage, and quality limit the opportunity for people with disabilities to fully intact with their communities, in violation of the core principle of inclusion, which is the basis of the Americans with Disabilities Act. 3. Description of activities: a. DRI will work to expand the access of individuals with disabilities to public and private transportation in the State of Iowa. To accomplish this, DRI will research access to transportation issues in Iowa and identify any limitations to employment, recreation or other types of personal needs; research state and federal law and cases involving accessibility of public and private transportation; Write a report with the information obtained on accessibility issues for individuals with disabilities in urban and rural areas of Iowa; Collaborate with grass roots groups and civil rights commissions throughout Iowa to draw attention to the issue; Meet with and provide training to transit providers regarding their obligations under the ADA and other accessibility laws; Represent individuals or groups of individuals in administrative hearings or legal actions regarding the failure of a public or private transportation entities to comply with the ADA or other accessibility laws; Identify solutions to implement accessible and dependable transportation within the greater metro, with the aim of eventually expanding and refining this model to rural communities. b. DRI will enforce the right of individuals with disabilities to have equal opportunities to access state and local government services, programs and activities. DRI will ensure that the state and municipalities of Iowa have an ADA coordinator; a self-evaluation, and a transition plan to bring their aids, benefits and services in compliance with the Americans with Disabilities Act, with attention paid both to physical accessibility as well as program access; Survey at least 10 smaller cities or towns to determine whether they are in compliance with the ADA with respect to physical disability and accessibility of materials; Provide individual and systemic legal advocacy concerning denial of equal access to state/local government services or other Title II public entities; Educate a diverse collection of community leaders on the benefits of incorporating universal design as a foundational element of community development, and advocate for its use statewide. c. DRI will enforce the right of individuals with disabilities to places of public accommodation, including but not limited to auditoriums, convention centers, lecture halls, or other place of public gathering. DRI will survey places of places of public gathering in at least three geographical areas in Iowa. including both rural and urban settings; provide trainings and technical assistance to owners and operators of places of public gathering; Collaborate with civil rights commissions and other municipal entities to ensure accessibility is considered as cities and smaller communities approve licenses and plans for places of public gathering; Provide legal advocacy or litigate cases concerning denial of equal access to places of public gathering. 4. Collaboration: See section IV-A for details of collaboration with U.S. Attorney’s office, local transit authority. 5. Number of cases: 12 Number of Class Actions: 0 6. Case summary: Client is a 56 year old man with neuropathy which inhibits his motor function. Client states that cars routinely park across from his driveway blocking his ability to get in and out of his house. Because of his disability, he needs to be able to park in his driveway to get in or out of his house, as he cannot walk more than short distances. DRI contacted city legal department, assisted with accommodation request for city to install a no parking sign across the street the client’s driveway. After about two months the client reported that the city had installed the sign and that it resolved his issue. Community Living: 1. Priority: Protect the Rights of Iowans to Live in the Most Integrated Setting 2. Need Addressed: Individuals with disabilities have the right under the Americans with Disabilities Act and the U.S. Supreme Court’s Olmstead decision to receive services in the most integrated settings within a reasonable timeframe. 3. Description of activities: a. DRI will work to increase the options of adults who want to live in the community rather than facilities to successfully transition to the community. To accomplish this, DRI will research and acquire knowledge of federal law regarding community integration of individuals in nursing facilities (MDS section Q referral process); Engage in meetings with Managed Care Organizations to monitor efforts being made to increase capacity of community based services system and hold them accountable for Olmstead violations when indicated; Represent individuals residing in nursing facilities or intermediate care facilities who wish to return to the community and are not receiving adequate transition planning; Review Pre-Admission Screening and Resident Review (PASRR) Level II Specialized Services and Care Plans of individuals in Nursing Facilities to ensure specialized services that would assist individuals in returning to the community are in place; Educate residents of nursing facilities and intermediate care facilities for individuals with intellectual disabilities about rights, including the right to participate in decisions about where they live and what services they receive and; Conduct monitoring of nursing facilities and intermediate care facilities for individuals with intellectual disabilities. b. DRI will work to increase the opportunities of adults on home and community-based service waivers, in settings where services are received 24 hours a day, to live and work in the community, have control over daily life decisions and choose what services they receive and who provides them. DRI will gain full understanding of state and federal oversight of HCBS Waiver programs; Provide advocacy to persons not receiving appropriate HCBS services; Monitor Iowa’s adherence to Statewide Transition Plan; Evaluate compliance with CMS’ home and community-based settings rule and take appropriate action to ensure compliance with the rule, including requesting Iowa Medicaid Enterprises to submit a setting through the heightened scrutiny process and; Monitor at least 6 24 hour HCBS settings. 4. Collaboration: DRI’s managed care class action litigation (section IV-B) is focused on ensuring that Medicaid recipients with disabilities continue to have access to the services necessary to receive care in their homes in the community and helping them avoid institutionalization. 5. Number of cases: 3 Number of Class Actions: 0 6. Case summary: Client is a 40 year old woman with a physical disability who uses a wheelchair and has limited use of her arms. Client’s home health provider discharged her and she lacked funding to hire her own staff. Her managed care organization was not helping her. DRI filed a grievance on the client’s behalf with the MCO and met with home health providers. Client received a new case manager, and after a level of care review was completed her level of care was increased. This allowed her to access provider care and she was able to continue receiving services in her home. Education: 1. Priority: Protect the Rights of Students with Disabilities 2. Need Addressed: Students with challenging behaviors related to their disability need to be in school and in their classroom all day so that they can receive specially designed instruction from qualified special educators. An appropriate behavior intervention plan not only helps a student access the general education curriculum but it also is the foundation for a successful transition to the community and post-secondary work. Research has shown that frequent use of suspensions or expulsions has no educational benefit, is strongly associated with low achievement, increases the risk of a student dropping out, and creates a greater likelihood of juvenile justice involvement. The use of seclusion and restraint, especially when it happens again and again for long periods of time, represents a failure of the behavior intervention plan. Students with disabilities are required by Iowa code to begin developing a transition plan at age 14. Standards set by the IDEA have been broken into three categories by the Iowa Department of Education living, learning and working. The three categories need to be meaningfully addressed in order to successfully transition to life in the community following the completion of graduation requirements. It is important to build the capacity of the Iowa attorney bar for parents/students so that there is more access to more skilled representation in the dispute resolution process in the Individuals with Disabilities in Education Act (IDEA). This, in turn, will lead to more positive educational outcomes for students with disabilities. 3. Description of Activities: DRI will provide suspended students assistance and legal advocacy developing appropriate goals and behavioral intervention plans that reduce the use of restraint, seclusion, and other exclusionary disciplinary measures. DRI will collaborate with the DOE, AEAs, and local education agencies to effect systemic change. DRI will work to ensure students in need of transition planning are receiving skill building and interest/work assessments, and provide legal advocacy/assistance to students whose transition plans were inadequately designed or implemented. If necessary, DRI will file due process or state complaints on behalf of individual students and their families. DRI will also work to train attorneys and law students on special education law and provide them technical assistance. 4. Collaboration: See section IV-A for description of collaboration with AEA’s, Dept. of Education, Vocational Rehabilitation, and the Center for Disabilities and Development. 5. Number of cases: 0 Number of Class Actions: 0 6. Case summary: DRI did not receive any requests for individual services in Education goals for PAIR eligible individuals this year. Our priority goals are two-year goals for FY17/FY18 and we will report on any education cases we receive in FY18. However, DRI continued to train a contract attorney on special education law to increase our capacity in handling cases and continued our presence on the Special Education Advisory Panel. DRI also was a partner in the Collaborative Work Group with the ASK Resource Center (Parent Training and Information) and Area Education Agencies (AEA) to develop training on the implementation of the Workforce Innovation Opportunity Act (WIOA) for students in school. This training is designed for parents, students and school staff. The training is available on all of the participants’ websites. DRI has had collaborative meetings with Grantwood AEA and the Northwest Area Education Association (NWAEA) to discuss the capacity of challenging behavior teams and to strategize researching the number of students on shortened school days. This project is in the early stages and is ongoing. The date collection will begin in FY18. DRI also began working with special education attorneys and the Department of Education to amend and improve the state regulations regarding the use of restraint and seclusion and will finalize this work in FY18. Employment: 1. Priority: Remove Barriers to Employment 2. Need Addressed: Individuals can do real work if they receive sufficient supports, services and reasonable accommodations. However, many individuals with disabilities wind up in sheltered workshops where only people with disabilities work—often at wages below minimum wage. Many of these individuals have realistic job expectations and prefer to do work where they have contacts with individuals without disabilities in the community. Congress enacted the Americans with Disabilities Act to prohibit discrimination against individuals with disabilities who can perform jobs, with reasonable accommodations or modifications of employment policies. However, many individuals with disabilities still experience discrimination or barriers to work. Therefore, it is important for DRI, as the protection and advocacy agency for Iowans with disabilities, to challenge discrimination so that individuals with disabilities can get and keep jobs and assist in an individual’s efforts to return to work. 3. Description of activities: a. DRI will assist individuals who want to move from sheltered work to competitive integrated jobs. DRI will monitor sheltered workshops for compliance with federal and state law and educate people with disabilities and their families about their legal rights (In conjunction with the Client Assistance Program in the Iowa Department of Human Rights); Educate rehabilitation professionals and educators about the changes in the laws which encourage integrated employment; Collaborate with other organizations who are promoting employment first and benefits planning in Iowa and; Provide legal representation to individuals in sheltered workshops who are not receiving services from Iowa Vocational Rehabilitation Services. b. DRI will work to stop employment discrimination because of a disability and remove barriers to work. DRI will teach applicants and employees how to file complaints with the Iowa Civil Rights Commission; Provide legally-based advocacy or representation to applicants or employees who need reasonable accommodations in their workplace or who have been terminated because of their disability; Provide legally-based advocacy or representation to beneficiaries of social security who received improper or inadequate services from an employment network, service provider, services provided by Iowa Vocational Rehabilitation, or other entity involved in the beneficiary’s return to work effort. 4. Collaboration: See employment trainings described in Section IB. 5. Number of cases: 6 Number of Class Actions: 0 6. Case summary: Client is a 36 year old man with chronic fatigue. Client works in a supply warehouse for a large international corporation. He was placed on unpaid leave after his FMLA leave was exhausted and he believed his employer plans to terminate him. He sought assistance returning to work. DRI obtained medical documentation in support of his ability to work with reasonable accommodations, contacted human resources and attorney for corporation, and requested they return client or reassign him. Employer put the client through a medical screening that confirmed his ability to return, then returned him to work with accommodations. Guardianship: 1. Priority: Reducing the number of Iowans with unnecessary or overly restrictive substitute decision makers. 2. Need addressed: People with disabilities are at disproportionate risk of having their right to make their own decisions and control their own lives stripped by courts or family members who believe their disability makes them incapable of doing so, or exposes them to risk of harm or exploitation. Though guardianships are intended to be limited and imposed only as a last resort, less restrictive alternatives and the legal obligations of guardians, their attorneys, and courts, are too often overlooked in practice. 3. Description of Activities: DRI will conduct outreach and training to schools, providers, and families to educate on alternatives to guardianship and supported decision making, and attend meetings of the Supreme Court’s Guardianship Reform Task Force. DRI will represent individuals to assist with terminating or resisting establishment of unnecessary or abusive guardianships/conservatorships or other substitute decision makers. DRI will create a basic guardianship training for attorneys to represent wards or prospective wards and provide technical assistance, and create resources for adult wards who want to self-advocate for less restrictive alternatives. 4. Collaboration: See substitute decision making trainings in Section IB and collaboration with judges and other attorneys on Guardianship and Conservatorship reform task force in Section IV-A. 5. Number of cases: 2 Number of Class Actions: 0 6. Case summary: The client is a 22 year old female with a kidney disorder. She lives with her guardian and would like to terminate the guardianship. DRI represented the client in an unsuccessful mediation and protracted litigation, including hearing on the client's petition to terminate. We filed a motion to modify an existing order when the client's guardian attempted to unlawfully evict her, in order to allow the client to safely move. We assisted with the appointment of a successor limited guardian who was much more effective, and then with termination once the successor guardian determined the guardianship was no longer necessary. Ultimately, the client had her guardianship terminated, moved to her own apartment, obtained control of her own SSI benefits, found a full time job, and has been thriving in the absence of a controlling guardian. Health Care: 1. Priority: Protect Access to Long-Term Services and Supports 2. Need Addressed: Iowa has recently privatized its Medicaid system. Medicaid recipients have many concerns about whether they will have the services they need under managed care, especially individuals receiving long-term services and supports. 3. Description of activities: DRI will provide legal representation in the grievance and appeal processes and in state fair hearings to individuals for whom specific long-term care services have been denied, reduced or terminated; address any systemic issues in managed care that are uncovered through advocacy or litigation (e.g. MCO’s not providing notice of decisions); provide advocacy to individuals needing long-term care services and who are on home and community-based waiver waiting lists to receive home and community-based services more promptly and; monitor managed care companies (MCOs) compliance with their contractual obligations with the State of Iowa to provide adequate long-term care services and supports in order to increase the number of individuals living in community based settings. 4. Collaboration: See section IV-B for description of collaboration with National Health Law Program and local civil rights firm in class action against the state over managed care. 5. Number of cases: 11 Number of Class Actions: 1 6. Case summary: The client is a 58 year old female diagnosed with peripheral neuropathy. The client came to DRI because her managed care organization was reducing her access to home health aide hours, skilled nursing hours, and access to specialty incontinence products. DRI represented the client both in the MCO appeal, and at a state fair hearing. The appeal yielded a satisfactory outcome pertaining to the client’s needed home health aide hours, and the state fair hearing yielded a favorable ruling on the clients medical need for her requested skilled nursing hours. Prior to the hearing DRI was able to get the clients MCO to agree in writing that the client had a medical need for her incontinence products and the MCO agreed to provide them in the quantities requested. As a result of DRI assistance client was provided with approval for all of her requested services and products. Housing: 1. Priority: Enforce the right of people with disabilities to have equal access to housing and increase affordable housing options. 2. Need addressed: Individuals with disabilities may experience a denial of equal access to public housing or encounter a landlord who will not provide a reasonable accommodation or otherwise discriminate against them due to a disability. In addition, on DRI’s public survey, approximately 70% of the people responding stated that DRI needs to focus on strategies to get more affordable housing for individuals with disabilities. As Priced Out 2014, a report published by the Technical Assistance Collaborative, Inc. and the Consortium for Citizens with Disabilities, Housing Task Force stated: There are few groups more adversely affected by rising rental costs and the acute shortage of decent, affordable rental homes than those non-elderly adults with serious and long-term disabilities who rely on SSI for their income. This unfortunate situation forces hundreds of thousands of people with disabilities to forego having a home of their own and to choose between homelessness or placement in a segregated and restrictive institutional setting. 3. Description of activities: DRI will represent individuals with disabilities whose landlords are not providing them with reasonable accommodations, or who have been or are about to be evicted based on their disabilities. DRI will participate in affordable housing coalitions in Iowa and research federal or state law on legal strategies to increase affordable housing. 4. Collaboration: Due to the reallocation of resources to focus on Medicaid Managed Care issues and the class action lawsuit DRI did not collaborate on any housing-related projects this year. 5. Number of cases: 2 Number of Class Actions: 0 6. Case summary: The client is a 38 year old man with liver cancer. Due to his recent diagnosis, client can no longer work and needs to move in with his girlfriend while he undergoes cancer treatment. He wanted assistance obtaining release from his rental agreement before the end of the lease. DRI contacted property manager and requested accommodation in the form of early lease termination on the client's behalf. Property manager agreed to release client from his lease.

B. Priorities and Objectives for the Current Fiscal Year

Please include a statement of priorities and objectives for the current fiscal year (the fiscal year succeeding that covered by this report), which should contain the following information:

  1. a statement of each prioirty;
  2. the need addressed by each priority; and;
  3. a description of the activities to be carried out under each priority.

Abuse and Neglect: 1. Priority: Keep Iowans with Disabilities Safe 2. Need Addressed: Working to reduce abuse and neglect in facilities, by investigating and monitoring is a core function of Disability Rights Iowa. Abuse and neglect is any act or failure to act, by a person with a duty to care for an individual with a disability in a facility or service setting, which caused or may have caused an injury or death. Facilities and service settings are locations where individuals with disabilities receive services such as treatment, programming, or residential supports. 3. Description of activities: DRI will conduct individual investigations into suspected abuse or neglect, including deaths and injuries of individuals with disabilities resulting from abuse or neglect in institutional and HCBS settings. DRI will monitor facilities or service settings with allegations of abuse or neglect, with histories of the same, or as a matter of routine course. DRI will provide rights trainings to individuals residing at the mental health institutes and a self-advocacy training to individuals with mental illness. DRI will provide individual advocacy including technical assistance, negotiation, or other assistance, to protect the rights of individuals with disabilities receiving services in facilities or service settings. DRI will provide individual representation including injunctive or administrative interventions. DRI will collaborate with the Department of Inspections and Appeals, the Long-Term Care Ombudsman and others to prevent abuse or neglect. DRI will work to improve the investigations of other enforcement and oversight agencies when they are inadequate, and issue public reports, where appropriate, to create systemic change. Accessibility: 1. Priority: Ensure Access to Services and Places 2. Need Addressed: Disability Rights Iowa remains committed to ensuring people with disabilities are given the opportunity to be full participants in every area of community life. However, we understand that opportunity in many cases is dependent on the availability of dependable and accessible transportation. Thousands of Iowans rely on accessible public and private transportation to meet their professional, personal, and recreational needs, and the capacity of those systems to meet demand are often woefully inadequate. Systemic deficits in both service coverage, and quality limit the opportunity for people with disabilities to fully intact with their communities, in violation of the core principle of inclusion, which is the basis of the Americans with Disabilities Act. 3. Description of activities: a. DRI will work to expand the access of individuals with disabilities to public and private transportation in the State of Iowa. To accomplish this, DRI will research access to transportation issues in Iowa and identify any limitations to employment, recreation or other types of personal needs; research state and federal law and cases involving accessibility of public and private transportation; Write a report with the information obtained on accessibility issues for individuals with disabilities in urban and rural areas of Iowa; Collaborate with grass roots groups and civil rights commissions throughout Iowa to draw attention to the issue; Meet with and provide training to transit providers regarding their obligations under the ADA and other accessibility laws; Represent individuals or groups of individuals in administrative hearings or legal actions regarding the failure of a public or private transportation entities to comply with the ADA or other accessibility laws; Identify solutions to implement accessible and dependable transportation within the greater metro, with the aim of eventually expanding and refining this model to rural communities. b. DRI will enforce the right of individuals with disabilities to have equal opportunities to access state and local government services, programs and activities. DRI will ensure that the state and municipalities of Iowa have an ADA coordinator; a self-evaluation, and a transition plan to bring their aids, benefits and services in compliance with the Americans with Disabilities Act, with attention paid both to physical accessibility as well as program access; Survey at least 10 smaller cities or towns to determine whether they are in compliance with the ADA with respect to physical disability and accessibility of materials; Provide individual and systemic legal advocacy concerning denial of equal access to state/local government services or other Title II public entities; Educate a diverse collection of community leaders on the benefits of incorporating universal design as a foundational element of community development, and advocate for its use statewide. c. DRI will enforce the right of individuals with disabilities to places of public accommodation, including but not limited to auditoriums, convention centers, lecture halls, or other place of public gathering. DRI will survey places of places of public gathering in at least three geographical areas in Iowa. including both rural and urban settings; provide trainings and technical assistance to owners and operators of places of public gathering; Collaborate with civil rights commissions and other municipal entities to ensure accessibility is considered as cities and smaller communities approve licenses and plans for places of public gathering; Provide legal advocacy or litigate cases concerning denial of equal access to places of public gathering. Community Living: 1. Priority: Protect the Rights of Iowans to Live in the Most Integrated Setting 2. Need Addressed: Individuals with disabilities have the right under the Americans with Disabilities Act and the U.S. Supreme Court’s Olmstead decision to receive services in the most integrated settings within a reasonable timeframe. 3. Description of activities: a. DRI will work to increase the options of adults who want to live in the community rather than facilities to successfully transition to the community. To accomplish this, DRI will research and acquire knowledge of federal law regarding community integration of individuals in nursing facilities (MDS section Q referral process); Engage in meetings with Managed Care Organizations to monitor efforts being made to increase capacity of community based services system and hold them accountable for Olmstead violations when indicated; Represent individuals residing in nursing facilities or intermediate care facilities who wish to return to the community and are not receiving adequate transition planning; Review Pre-Admission Screening and Resident Review (PASRR) Level II Specialized Services and Care Plans of individuals in Nursing Facilities to ensure specialized services that would assist individuals in returning to the community are in place; Educate residents of nursing facilities and intermediate care facilities for individuals with intellectual disabilities about rights, including the right to participate in decisions about where they live and what services they receive and; Conduct monitoring of nursing facilities and intermediate care facilities for individuals with intellectual disabilities. b. DRI will work to increase the opportunities of adults on home and community-based service waivers, in settings where services are received 24 hours a day, to live and work in the community, have control over daily life decisions and choose what services they receive and who provides them. DRI will gain full understanding of state and federal oversight of HCBS Waiver programs; Provide advocacy to persons not receiving appropriate HCBS services; Monitor Iowa’s adherence to Statewide Transition Plan; Evaluate compliance with CMS’ home and community-based settings rule and take appropriate action to ensure compliance with the rule, including requesting Iowa Medicaid Enterprises to submit a setting through the heightened scrutiny process and; Monitor at least 6 24 hour HCBS settings. Education: 1. Priority: Protect the Rights of Students with Disabilities 2. Need Addressed: Students with challenging behaviors related to their disability need to be in school and in their classroom all day so that they can receive specially designed instruction from qualified special educators. An appropriate behavior intervention plan not only helps a student access the general education curriculum but it also is the foundation for a successful transition to the community and post-secondary work. Research has shown that frequent use of suspensions or expulsions has no educational benefit, is strongly associated with low achievement, increases the risk of a student dropping out, and creates a greater likelihood of juvenile justice involvement. The use of seclusion and restraint, especially when it happens again and again for long periods of time, represents a failure of the behavior intervention plan. Students with disabilities are required by Iowa code to begin developing a transition plan at age 14. Standards set by the IDEA have been broken into three categories by the Iowa Department of Education living, learning and working. The three categories need to be meaningfully addressed in order to successfully transition to life in the community following the completion of graduation requirements. It is important to build the capacity of the Iowa attorney bar for parents/students so that there is more access to more skilled representation in the dispute resolution process in the Individuals with Disabilities in Education Act (IDEA). This, in turn, will lead to more positive educational outcomes for students with disabilities. 3. Description of Activities: DRI will provide suspended students assistance and legal advocacy developing appropriate goals and behavioral intervention plans that reduce the use of restraint, seclusion, and other exclusionary disciplinary measures. DRI will collaborate with the DOE, AEAs, and local education agencies to effect systemic change. DRI will work to ensure students in need of transition planning are receiving skill building and interest/work assessments, and provide legal advocacy/assistance to students whose transition plans were inadequately designed or implemented. If necessary, DRI will file due process or state complaints on behalf of individual students and their families. DRI will also work to train attorneys and law students on special education law and provide them technical assistance. Employment: 1. Priority: Remove Barriers to Employment 2. Need Addressed: Individuals can do real work if they receive sufficient supports, services and reasonable accommodations. However, many individuals with disabilities wind up in sheltered workshops where only people with disabilities work—often at wages below minimum wage. Many of these individuals have realistic job expectations and prefer to do work where they have contacts with individuals without disabilities in the community. Congress enacted the Americans with Disabilities Act to prohibit discrimination against individuals with disabilities who can perform jobs, with reasonable accommodations or modifications of employment policies. However, many individuals with disabilities still experience discrimination or barriers to work. Therefore, it is important for DRI, as the protection and advocacy agency for Iowans with disabilities, to challenge discrimination so that individuals with disabilities can get and keep jobs and assist in an individual’s efforts to return to work. 3. Description of activities: a. DRI will assist individuals who want to move from sheltered work to competitive integrated jobs. DRI will monitor sheltered workshops for compliance with federal and state law and educate people with disabilities and their families about their legal rights (In conjunction with the Client Assistance Program in the Iowa Department of Human Rights); Educate rehabilitation professionals and educators about the changes in the laws which encourage integrated employment; Collaborate with other organizations who are promoting employment first and benefits planning in Iowa and; Provide legal representation to individuals in sheltered workshops who are not receiving services from Iowa Vocational Rehabilitation Services. b. DRI will work to stop employment discrimination because of a disability and remove barriers to work. DRI will teach applicants and employees how to file complaints with the Iowa Civil Rights Commission; Provide legally-based advocacy or representation to applicants or employees who need reasonable accommodations in their workplace or who have been terminated because of their disability; Provide legally-based advocacy or representation to beneficiaries of social security who received improper or inadequate services from an employment network, service provider, services provided by Iowa Vocational Rehabilitation, or other entity involved in the beneficiary’s return to work effort. Guardianship: 1. Priority: Reducing the number of Iowans with unnecessary or overly restrictive substitute decision makers. 2. Need addressed: People with disabilities are at disproportionate risk of having their right to make their own decisions and control their own lives stripped by courts or family members who believe their disability makes them incapable of doing so, or exposes them to risk of harm or exploitation. Though guardianships are intended to be limited and imposed only as a last resort, less restrictive alternatives and the legal obligations of guardians, their attorneys, and courts, are too often overlooked in practice. 3. Description of Activities: DRI will conduct outreach and training to schools, providers, and families to educate on alternatives to guardianship and supported decision making, and attend meetings of the Supreme Court’s Guardianship Reform Task Force. DRI will represent individuals to assist with terminating or resisting establishment of unnecessary or abusive guardianships/conservatorships or other substitute decision makers. DRI will create a basic guardianship training for attorneys to represent wards or prospective wards and provide technical assistance, and create resources for adult wards who want to self-advocate for less restrictive alternatives. Health Care: 1. Priority: Protect Access to Long-Term Services and Supports 2. Need Addressed: Iowa has recently privatized its Medicaid system. Medicaid recipients have many concerns about whether they will have the services they need under managed care, especially individuals receiving long-term services and supports. 3. Description of activities: DRI will provide legal representation in the grievance and appeal processes and in state fair hearings to individuals for whom specific long-term care services have been denied, reduced or terminated; address any systemic issues in managed care that are uncovered through advocacy or litigation (e.g. MCO’s not providing notice of decisions); provide advocacy to individuals needing long-term care services and who are on home and community-based waiver waiting lists to receive home and community-based services more promptly and; monitor managed care companies (MCOs) compliance with their contractual obligations with the State of Iowa to provide adequate long-term care services and supports in order to increase the number of individuals living in community based settings. Housing: 1. Priority: Enforce the right of people with disabilities to have equal access to housing and increase affordable housing options. 2. Need addressed: Individuals with disabilities may experience a denial of equal access to public housing or encounter a landlord who will not provide a reasonable accommodation or otherwise discriminate against them due to a disability. In addition, on DRI’s public survey, approximately 70% of the people responding stated that DRI needs to focus on strategies to get more affordable housing for individuals with disabilities. As Priced Out 2014, a report published by the Technical Assistance Collaborative, Inc. and the Consortium for Citizens with Disabilities, Housing Task Force stated: There are few groups more adversely affected by rising rental costs and the acute shortage of decent, affordable rental homes than those non-elderly adults with serious and long-term disabilities who rely on SSI for their income. This unfortunate situation forces hundreds of thousands of people with disabilities to forego having a home of their own and to choose between homelessness or placement in a segregated and restrictive institutional setting. 3. Description of activities: DRI will represent individuals with disabilities whose landlords are not providing them with reasonable accommodations, or who have been or are about to be evicted based on their disabilities. DRI will participate in affordable housing coalitions in Iowa and research federal or state law on legal strategies to increase affordable housing

Part VI. Narrative

At a minimum, you must include all of the information requested. You may include any other information, not otherwise collected on this reporting form that would be helpful in describing the extent of PAIR activities during the prior fiscal year. Please limit the narrative portion of this report, including attachments, to 20 pages or less.

The narrative should contain the following information. The instructions for this form outline the information that should be contained in each section.

  1. Sources of funds received and expended
  2. Budget for the fiscal year covered by this report
  3. Description of PAIR staff (duties and person-years)
  4. Involvement with advisory boards (if any)
  5. Grievances filed under the grievance procedure
  6. Coordination with the Client Assistance Program (CAP) and the State long-term care program, if these programs are not part of the P&A agency

A. Sources of funds Received: Department of Education 2016-17 Grant Award 171,598.00 2015-2016 Carryover Grant Funds 18,414.74 Sub-total 190,012.74 Program Income 3,817.60 Total Sources of Funds 193,830.34 Expended: 185,896.82 B. Budget for the fiscal year covered by this report: FY17 FY18 Projected Salaries 127,899.21 119,174.00 Fringe Benefits 25,182.81 22,517.00 Materials/Supplies 3,039.14 1,279.00 Postage 240.80 338.00 Telephone 585.17 555.00 Rent 15,735.58 14,071.00 Travel 2,337.49 1,538.00 Copying 801.91 930.00 Insurance 3,530.95 3,651.00 Legal Services - 54.00 Litigation Cost - 7,000.00 Miscellaneous 2,692.50 2,000.00 Professional Services 3,851.27 4,081.00 Total 185,896.82 177,188.00 C. Description of PAIR staff: Attorneys 51% Advocates 16% Paralegal 11% Mgmt/Finance 22% D. DRI sits on the following boards or workgroups Supreme Court Guardianship/Conservatorship Reform Task Force Special Education Advisory Panel Collaborative Work Group with ASK Resource Center and AEAs Facility Crisis and Closure Team Disability Access Committee Association of People Supporting Employment First Developmental Disability Council Mental Health Conference Planning Committee Iowa Legal Aid Central Iowa Regional Advisory Council Iowa Advisory Committee to the U.S. Civil Rights Commission Iowa Law and Service Together Coordinated Community Response to Elder Abuse Sexual Expression in Long Term Care Task Force Elder Justice Task Force Iowa Therapeutic Alternatives to Incarceration Coalition Governor’s Commission on Persons with Disabilities Advisory Council on Brain Injury Parent Attorney Workgroup Elder Law Section of Iowa State Bar Association Family and Juvenile Law Section of Iowa State Bar Association Probate Law Section of Iowa State Bar Association Advisory Board for gender-specific after-school program at Children and Family Urban Movement Iowa Girls Justice Initiative E. DRI had two grievances filed in 2017. The first was in a case about an individual who alleged questions about English proficiency on a hotel chain’s employment application constituted disability discrimination. The second was for an individual seeking representation in an employment discrimination lawsuit. The board of directors reviewed both cases and agreed with DRI’s decision to decline representation. F. DRI continues to have a good working relationship with the state Long Term Care Ombudsman’s office and collaborated this year on monitorings and to address concerns of residents in nursing facilities. LTCO has recently been subject to budget cuts that restricts their ability to meet clients face to face and as such we expect they will refer more cases to DRI for investigation or monitoring in the coming year. DRI and the Client Assistance Program have worked together in the past on projects and continue to communicate and refer cases to one another as appropriate. DRI and CAP are also both members of the Iowa Coalition for Integrated Employment.

Certification

Signed?Yes
Signed ByCynthia A. Miller
TitleLegal Director
Signed Date12/15/2017