In PSH for chronically homeless people it is likely that some tenants meet clinical needs-based eligibility criteria for HCBS, while other tenants who are less disabled may not be eligible to receive these services.
All people served by 1915c waiver programs must meet service criteria equivalent to the criteria used to determine eligibility for institutional care in a hospital nursing facility, nursing home, or similar level of care. While these criteria vary significantly from one state to another, they take into consideration the type and severity of functional limitations, including needs for assistance in activities of daily living (ADL) and instrumental activities of daily living (IADL),31and/or needs for medical and nursing care. It is not necessary for a person to be institutionalized or staying in a nursing home to qualify for HCBS services, but a formal (independent) assessment process is required to determine that a person meets the applicable criteria for institutional care or HCBS waiver services.
As described in Section 6.2, the purpose of 1915i is to expand access to HCBS to persons with disabilities who are not at an institutional level of care, so the needs-based criteria that states establish for these services are less stringent than the criteria for institutional services.