Massachusetts: VOR objects to eligibility criteria based solely on IQ and Agency determination
November 13, 2012
Please accept these comments in response to the emergency regulations issued by the Department of Developmental Services (DDS) regarding eligibility of DDS clients for services at 115 CMR 1.02, 115 CMR 2.01 and 115 CMR 6.02, which became effective September 26, 2012.
We are specifically concerned about 115 CMR 1.02 which reads:
The Department [of Developmental Services] is the clinical authority that determines the presence or absence of intellectual disability using the standard set forth at page 5 in the 11th edition of the American Association on Intellectual and Developmental Disabilities
We share the concerns expressed by our statewide affiliate COFAR, our affiliate CCMR, families of individuals with I/DD, and others who uniformly express concern about these proposed regulations.