ABCD Submits Comments on Regulations

Published On: August 30th, 2022Categories: News

The Division of Family Development which administers the NJ SNAP program accepted public comment prior to their internal deliberations on amending the regulations, called Advance Notice of Rulemaking.  In response, ABCD asked for clarification in the regulations to ensure that all counties are operating at the same level of service with respect to reasonable accommodation, to make permanent and statewide the pilot which permits SNAP recipients to purchase food on-line, and to consider allowing the SNAP program to pay for food delivery services (this last request will require federal approval).

ABCD also submitted comments on proposed regulations for Community Residences for IDD. Our suggestions included changing “procedures for the use of surveillance cameras’ to “procedures for the use of communication technology;” insisting DDD define what information in the client’s record is the property of DHS; calling for the Planning Team, not the Division, to make the determination if residence is no longer suitable for the individual and that the process be concrete, standardized, and consider the needs of the individual and their residential community (the people who live and work with them); that additional fire safety precautions be determined by the professionals in DCA and local fire marshal and not the Office of Licensing; that there be 48 hours in which to review,  revise and practice an emergency evacuation plan with new admissions; clarification on the requirement for standby generators and, if required, funding must be provided; questioning the proposed requirement for water tight garbage containers if town’s disposal vessel is not waterproof or if residence uses small dumpster; asking how a residence can have 3 days’ worth of food at all times including on the day before grocery shopping; the physician’s “order” for DME be changed to physician’s  “prescription” for DME; and that “gender” be changed to “gender identity.”

ABCD also submitted comments on the proposed regulations for Community Care Residence. Our suggestions included that since CCR’s do not employ direct care staff, the state’s rationale that a portion of the Komnino’s Law be applied is incorrect; asking how the state could possibly make the case that increased requirements/expenses have been incorporated into funding from the department when the rate has not increased in over 10 years.

Picture provided by LADACIN

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