Difficulty of Care: Operational Challenges and Considerations

In April 2023, Applied Self-Direction held a member forum for Financial Management Services (FMS) members. During this forum, attendees identified ambiguities of Notice 2014-7, including the application of Notice 2014-7 for Home and Community-Based Services beyond those funded by 1915(c) waivers, the ongoing confusion surrounding workers being exempt from taxes while also qualifying for Difficulty of Care and how to differentiate the two, the roles and responsibilities of the FMS, ways to avoid potential fraud, and how to accurately report and provide information about the benefit of Difficulty of Care. This resource summarizes the discussion to clarify these perplexities.