Georgia Medicaid HCBS Waivers (2026): CCSP, SOURCE, NOW, COMP, ICWP

Audience: Georgia families navigating long-term services and supports for an older parent, a spouse with disabilities, or a child with developmental disabilities; individuals at risk of nursing facility placement who want to stay at home; people transitioning from hospital or rehab and trying to avoid institutionalization; advocates and case managers working with Medicaid waiver populations.

What this guide covers: What Home and Community-Based Services (HCBS) waivers are and how Section 1915(c) of the Social Security Act lets states pay for community-based long-term services. The five major Georgia HCBS waivers: the Community Care Services Program (CCSP) for frail older adults and adults with physical disabilities; Service Options Using Resources in a Community Environment (SOURCE) for primary care case management of dual eligibles and ABD beneficiaries; the New Options Waiver (NOW) and the Comprehensive Supports Waiver Program (COMP) for adults with intellectual and developmental disabilities; and the Independent Care Waiver Program (ICWP) for adults age 21 to 64 with severe physical disabilities. The Georgia Pediatric Program (GAPP) for medically fragile children. The Katie Beckett TEFRA pathway that lets a child with disabilities qualify for Medicaid based on her own income rather than her parents'. The CMS HCBS Settings Final Rule that established community-integration requirements at 42 CFR 441.301(c)(4). The Olmstead v. L.C. Supreme Court decision and the 2010 USDOJ Settlement Agreement that anchor Georgia's community-integration mandate. Section 1924 spousal impoverishment protections for HCBS waiver applicants. Money Follows the Person, Community First Choice (Section 1915(k)), state plan HCBS (Section 1915(i)), and self-directed services (Section 1915(j)). Electronic Visit Verification under Section 12006 of the Cures Act. Six worked examples covering CCSP enrollment, ICWP for a younger adult with MS, NOW waiver navigation for a child with autism, SOURCE post-acute coordination, COMP placement after a family caregiver's health decline, and an Olmstead-grounded nursing-home diversion. A 14-question FAQ. And a contact list with the key Georgia phone numbers including the Olmstead Hotline, ADRC, DBHDD Intake, and Disability Rights Georgia.

By Brevy Care Team · Last verified May 12, 2026

The American Medicaid program was designed in 1965 around institutional long-term care. Until 1981, if Medicaid was going to pay for personal support, skilled nursing, or supervised living for an older adult or a person with disabilities, it generally had to be in a nursing facility or an intermediate care facility for individuals with intellectual disabilities (ICF/IID). The federal Medicaid State Plan covered limited home health (skilled, intermittent) and very narrow personal care, but the bulk of long-term services and supports flowed through institutions.

This created two problems. First, it was expensive: nursing facility care typically costs far more than equivalent community-based services. Second, and more important, it conflicted with the lived preferences of the people Medicaid was supposed to serve. Older adults and people with disabilities overwhelmingly preferred to live at home, in their own communities, with family and neighbors, rather than in institutions.

Section 2176 of the Omnibus Budget Reconciliation Act of 1981 changed this by creating Section 1915(c) of the Social Security Act: the "Home and Community-Based Services waiver" authority. Section 1915(c) allows states to ask the Centers for Medicare and Medicaid Services (CMS) for a waiver of three specific Medicaid State Plan requirements:

• Statewideness: the waiver can be geographically limited
• Comparability: the services in the waiver can differ from the regular State Plan
• Income and resource methodology: the state can use the more generous institutional rules (300 percent of the SSI Federal Benefit Rate) for waiver applicants

In exchange, the state must demonstrate three "assurances": cost-neutrality (the waiver must not cost more than institutional care would have); health and welfare safeguards (the state must ensure participants' safety); and a quality assurance plan. The waiver is approved for an initial five-year term and renewed thereafter.

Section 1915(c) has been the workhorse authority for community-based long-term services for over four decades. As of 2024, Georgia operates five major Section 1915(c) waivers plus the Georgia Pediatric Program and Katie Beckett TEFRA pathway. Together, these waivers serve tens of thousands of Georgians in their homes and communities, with many more on waiting lists.

The Olmstead v. L.C. decision in 1999 added a constitutional dimension. The Supreme Court held that the Americans with Disabilities Act prohibits "unjustified institutional isolation of persons with disabilities," requiring states to provide services in the most integrated setting appropriate. This made HCBS waivers not just a budget tool but a civil rights mechanism. Georgia signed a USDOJ Settlement Agreement in October 2010 committing to specific community-integration goals for individuals with intellectual/developmental disabilities and mental illness, and that agreement continues to drive waiver capacity expansion.

This guide explains how each Georgia HCBS waiver works, who qualifies, how to apply, and how to navigate waiting lists, service planning, and appeals. It is informational and does not constitute legal, medical, or insurance advice; eligibility, services, and waiting list dynamics change. Confirm specifics with the Georgia Department of Community Health (DCH), the Georgia Department of Behavioral Health and Developmental Disabilities (DBHDD), or qualified counsel.

The federal HCBS authority framework

Five federal authorities allow Medicaid to pay for HCBS:

Section 1915(c), the traditional HCBS waiver. The original authority, enacted 1981. Allows waivers of statewideness, comparability, and institutional income methodology for individuals meeting institutional level of care. States may cap enrollment (waiting lists are allowed). Implementing regulations at 42 CFR 441 Subpart G. Each waiver is a five-year approved package of services for a defined target population. The five Georgia waivers above all operate under §1915(c).

Section 1915(i), state plan HCBS. Added by the Deficit Reduction Act 2005 and expanded by the ACA. Unlike §1915(c), §1915(i) does not require institutional level of care; participants must meet a state-defined functional need. Income limit is set within federal parameters. States cannot maintain waiting lists for §1915(i): if you qualify, the state must serve you. 42 CFR 441.350-441.365.

Section 1915(j), self-directed personal assistance. "Cash and counseling" model. Allows participants to manage their own personal care budget, hire family caregivers (in some cases), and direct services. 42 CFR 441.450-441.484.

Section 1915(k), Community First Choice (CFC). Added by ACA §2401. State plan option for attendant services and supports. Receives an enhanced federal matching payment (FMAP) boost. Person-centered planning required. Georgia has not yet adopted CFC.

Section 1115 demonstration waivers. Broader research and demonstration authority. Some states use §1115 to operate managed long-term services and supports (MLTSS) programs. Georgia uses §1115 for the Pathways to Coverage program but not for MLTSS.

Most of Georgia's HCBS infrastructure runs through §1915(c). The discussion below focuses primarily on the five §1915(c) waivers operating in Georgia.

CCSP: Community Care Services Program

The Community Care Services Program is Georgia's HCBS waiver for frail older adults and adults under 65 with physical disabilities. It is one of Georgia's longest-running waivers.

Who qualifies. CCSP eligibility requires:

• Age 65 or older, OR adult under 65 with a physical disability
• Meeting nursing-home-level-of-care (NHLOC) criteria, determined via a Determination of Need-Revised (DON-R) assessment
• Medicaid-eligible: either through regular ABD Medicaid income and resource standards, or through the special institutional income methodology (300 percent of the SSI Federal Benefit Rate), with patient liability applied above the SSI benefit level
• Resources within ABD Medicaid limits, with Section 1924 spousal impoverishment protection for married applicants

Services covered. CCSP includes:

• Personal Support Services (PSS): non-skilled assistance with activities of daily living (bathing, dressing, toileting, transferring, feeding) and instrumental ADLs (meal prep, light housekeeping)
• Adult Day Health (ADH): community-based day program providing structured care, meals, activities, health monitoring
• Personal Emergency Response System (PERS): wearable alert button connected to 24/7 response
• Home-Delivered Meals (HDM): typically 5 meals per week
• Skilled Nursing: intermittent skilled nursing for specific tasks
• Out-of-Home Respite: temporary nursing facility stay for caregiver respite
• Alternative Living Services (ALS): small group home setting
• Specialized Medical Equipment: limited DME
• Service Coordination: case management to coordinate the plan

How to apply. Call the Aging and Disability Resource Connection (ADRC) at 1-866-552-4464. The ADRC will refer to one of the 12 regional Area Agencies on Aging (AAA), which conduct intake and the DON-R assessment.

Waiting list. CCSP maintains regional waiting lists that fluctuate by AAA region. Wait times can range from a few weeks (in regions with available slots) to many months. Post-acute hospital discharge applicants and crisis cases receive priority.

Cost neutrality. The waiver must demonstrate that per-participant cost is less than or equal to what nursing facility care would have cost. CCSP services are typically a substantial savings to the state compared to institutional placement; pull current Georgia DCH fee-schedule and nursing-facility per-diem rates for finalized figures.

Service planning. A care coordinator from the AAA develops a person-centered service plan with the participant and family, identifying services, providers, hours, and frequency. The plan is reviewed annually and modified when needs change.

SOURCE: Service Options Using Resources in a Community Environment

SOURCE is different from the other waivers in that it is primarily a primary care case management (PCCM) overlay rather than a free-standing HCBS waiver. It serves ABD Medicaid beneficiaries (and may overlap with CCSP for LTSS components).

Who qualifies. ABD Medicaid enrollees who need care coordination, particularly:

• Frail older adults
• Adults with disabilities
• Dual eligibles needing coordination across Medicare and Medicaid

What SOURCE does.

• Assigns a care coordinator to the enrollee
• Coordinates primary care, specialty care, and (for duals) Medicare benefits
• Develops a written service plan
• Monitors care plan adherence
• Coordinates referrals to CCSP for waiver-funded LTSS

No waiting list. Unlike CCSP, NOW, COMP, and ICWP, SOURCE does not maintain a waiting list. Enrollment is open to qualifying ABD Medicaid beneficiaries.

Combination with CCSP. A common pattern: an enrollee has SOURCE for care coordination and CCSP for waiver-funded LTSS. The SOURCE coordinator helps initiate the CCSP referral, manages care across both, and coordinates with Medicare for medical care if the enrollee is a dual.

NOW: New Options Waiver

NOW is one of Georgia's two waivers for adults with intellectual and developmental disabilities (I/DD). It is administered by the Department of Behavioral Health and Developmental Disabilities (DBHDD).

Who qualifies.

• Adults age 18 or older (some pediatric service available)
• Diagnosed I/DD (intellectual disability, autism with associated functional needs, traumatic brain injury before age 22, etc.)
• Meeting ICF/IID level of care (a higher bar than NHLOC; requires significant adaptive functioning deficits in specific domains)
• Medicaid-eligible (typically ABD or, for children, Katie Beckett TEFRA)
• Living in the community

Services covered.

• Community Access (Group): structured activities in community settings, typically 5 days per week
• Community Access (Individual): one-on-one community supports
• Supported Employment: job coaching, employment supports
• Community Living Support (CLS): in-home supports
• Community Residential Alternative (CRA): small group home setting (4 or fewer residents typically)
• Respite Care: in-home or out-of-home respite for family caregivers
• Transportation: non-medical transport for waiver activities
• Specialized Medical Equipment / Supplies
• Behavioral Supports: behavior management, training, intervention
• Adult Therapies: PT, OT, speech beyond Medicare/Medicaid State Plan
• Support Coordination: care management

Cost cap. NOW operates under a per-participant cost cap; contact DBHDD for current figures.

Waiting list. NOW and COMP share a combined waiting list managed by DBHDD. Wait times can be significant; crisis prioritization is available for individuals at imminent risk of institutionalization.

How to apply. Call DBHDD Intake at 1-888-273-1414. The intake worker conducts initial screening and connects to the regional Field Office for assessment.

COMP: Comprehensive Supports Waiver Program

COMP is the second I/DD waiver in Georgia, serving adults whose needs exceed NOW's cost cap or service intensity.

Who qualifies. Same eligibility as NOW (age 18+, I/DD, ICF/IID LOC, Medicaid-eligible) but with significantly higher service needs:

• 24/7 supervision requirements
• Intensive behavioral supports
• Skilled nursing for specific health conditions
• Complex medical needs

Services covered. All NOW services plus:

• 24/7 Community Residential Alternative (CRA): small group home with around-the-clock staffing
• Host Home: family-living arrangement with trained host
• Intensive Behavioral Supports: specialized behavior services
• Skilled Nursing: more comprehensive than NOW
• Specialized Medical Supplies / Equipment more comprehensive

No fixed cost cap (unlike NOW); services are based on assessed need within statewide cost-neutrality.

ICF/IID alternative. COMP serves as the community-based alternative to ICF/IID institutional placement. Olmstead Plan commitments call for continued movement from ICF/IIDs to COMP.

Same waiting list as NOW. Combined waiting list managed by DBHDD; contact DBHDD for current wait list status.

ICWP: Independent Care Waiver Program

ICWP serves adults age 21 to 64 with severe physical disabilities. The age cutoff matters because it fills a gap: CCSP serves 65+ and adults under 65 with disabilities (with some overlap), but ICWP is specifically tailored to the working-age adult with significant physical disability.

Who qualifies.

• Age 21 to 64
• Severe physical disability (commonly: spinal cord injury, traumatic brain injury, multiple sclerosis, ALS, muscular dystrophy, cerebral palsy)
• Meeting nursing-home-level-of-care OR hospital level of care criteria
• ABD Medicaid eligible
• Spousal impoverishment under §1924 if married

Services covered.

• Personal Support Services (PSS): typically 30-60 hours per week, sometimes more
• Personal Emergency Response System (PERS)
• Adult Day Health
• Skilled Nursing
• Specialized Medical Equipment
• Counseling: behavioral health
• Case Management
• Alternative Living Services

How to apply. ADRC at 1-866-552-4464 will refer to the contracted ICWP case management entity.

Waiting list. ICWP has historically maintained a waiting list.

GAPP: Georgia Pediatric Program

The Georgia Pediatric Program covers medically fragile and technology-dependent children. Authority varies (§1915(c) for some components, §1115 for others; recently restructured).

Who qualifies.

• Under age 21
• Medically complex/fragile (commonly: ventilator dependence, tracheostomy, GI tube feeding, complex seizure disorders, traumatic brain injury, complex congenital conditions)
• Requires skilled nursing care
• Meets hospital or nursing facility level of care criteria

Services covered.

• Private Duty Nursing (PDN): up to 24 hours per day depending on assessed need
• Personal Care Services
• Specialized Medical Equipment
• Family Training and Support
• Case Management

Common combination with Katie Beckett. Many GAPP-eligible children also access Medicaid through the Katie Beckett TEFRA pathway because their family incomes exceed regular Medicaid eligibility.

Katie Beckett TEFRA pathway

The Katie Beckett pathway is not technically an HCBS waiver but an eligibility category, authorized by Section 1902(e)(3) of the Social Security Act and the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA). It is named after Katie Beckett, a child with disabilities whose case under the Reagan administration prompted the legislation.

The problem Katie Beckett solves. Under regular Medicaid eligibility, a child's eligibility depends on family income. A family above the income limit cannot get Medicaid for their child. But for a medically fragile child, Medicaid is often the only payer for the level of care required, especially private duty nursing or extensive therapies. The Katie Beckett pathway lets a child with significant disabilities qualify based on the child's own income and resources (typically zero), even if the parents' income is far above the regular limit.

Who qualifies.

• Under age 19
• Would qualify for Medicaid if institutionalized (meets ICF/IID or hospital LOC)
• Receiving care at home is appropriate
• Cost of home care does not exceed the cost of institutional care

How to apply. DCH Katie Beckett unit; coordinate with DBHDD or DCH HCBS Unit for accompanying waiver application.

Common combination. Katie Beckett eligibility for Medicaid; NOW or COMP waiver for services; GAPP for nursing care. Each is a separate application/approval.

The CMS HCBS Settings Final Rule

The CMS HCBS Final Rule restructured the federal framework for HCBS settings. Codified at 42 CFR 441.301(c)(4), the rule established that HCBS settings must meet specific community-integration criteria. The rule applies to all §1915(c) waivers and §1915(i) state plan HCBS.

Core settings requirements.

1. The setting is integrated in and supports full access to the greater community
2. The setting is selected by the individual from among setting options
3. The setting ensures the individual's rights of privacy, dignity, and respect, and freedom from coercion and restraint
4. The setting optimizes individual initiative, autonomy, and independence
5. The setting facilitates individual choice regarding services, supports, and providers

Additional requirements for provider-owned or controlled residential settings:

• A legally enforceable agreement or lease providing eviction protections equivalent to the state's landlord-tenant law
• Privacy in the individual's living unit (lockable entrance door, sharing only by choice)
• Choice of roommates
• Freedom to furnish/decorate
• Freedom to control schedule and activities
• Access to food at any time
• Visitors at any time
• Physical accessibility

Heightened scrutiny. Settings presumed to be institutional (such as those located on the grounds of an institution, in a building on a public institutional campus, or with characteristics that effectively isolate participants) face additional scrutiny. The state must demonstrate that these settings are HCBS-eligible despite the institutional presumption, or the settings cannot be used for HCBS.

Statewide Transition Plan (STP). Each state submitted a transition plan to CMS detailing how it would bring all its HCBS settings into compliance. Georgia's STP was approved by CMS and implemented through DCH and DBHDD. The compliance deadline was extended several times before taking full effect.

Practical impact in Georgia. Day habilitation programs that were segregated have been restructured to support community-integration. Group home leases now meet the lease requirement. Sheltered workshops have largely phased out (though some still operate under DOL sub-minimum wage waivers). Member access to food, schedule autonomy, and visitor rights have been formalized in policy.

Olmstead v. L.C. and Georgia's USDOJ Settlement

The Olmstead v. L.C. decision (527 U.S. 581, 1999) is the constitutional foundation for community-based HCBS in the United States. The case involved two women with mental illness and developmental disabilities who were institutionalized in a Georgia state psychiatric hospital. They argued that, having been determined by treatment professionals to be appropriate for community placement, their continued institutionalization violated Title II of the Americans with Disabilities Act, which prohibits discrimination by public entities.

The Supreme Court agreed. Writing for the majority, Justice Ginsburg held that "unjustified institutional isolation of persons with disabilities is a form of discrimination." She established a three-part test for community placement:

1. The state's treatment professionals determine that community placement is appropriate
2. The affected person does not oppose community placement
3. The state can reasonably accommodate, taking into account the resources available and the needs of others with disabilities

The "reasonable accommodation" prong gave states significant flexibility, but the underlying principle is clear: states have an affirmative obligation to serve people with disabilities in the most integrated setting appropriate to their needs.

The 2010 Georgia USDOJ Settlement. In 2009, the U.S. Department of Justice sued Georgia for over-institutionalization of individuals with intellectual/developmental disabilities and mental illness in state psychiatric hospitals and ICF/IIDs. In October 2010, Georgia signed a comprehensive settlement agreement committing to:

• Transition individuals from state psychiatric hospitals to community settings
• Expand HCBS waiver capacity (especially NOW and COMP) for individuals with I/DD
• Develop crisis services (mobile crisis teams, crisis stabilization units, crisis service centers)
• Expand supported employment
• Develop supported housing
• Establish independent monitoring with periodic court reports

Settlement implementation continues through the present. Disability Rights Georgia and the USDOJ Civil Rights Division continue to monitor compliance. Periodic court filings document progress and gaps.

Olmstead Hotline. Georgia operates an Olmstead Hotline at 1-844-292-1531. Individuals at risk of unnecessary institutionalization (or already institutionalized and wishing to transition) can call. The hotline connects to ADRC for waiver pathway exploration and to DBHDD for I/DD-specific transitions.

Section 1924 spousal impoverishment for HCBS waivers

When one spouse needs HCBS waiver services, Section 1924 of the Social Security Act, also called the Medicaid Catastrophic Coverage Act spousal impoverishment provisions, protects the community spouse's financial security. Section 1924 was originally enacted in 1988 for nursing facility applicants; the Deficit Reduction Act 2005 gave states the option to extend §1924 to HCBS waiver applicants. Georgia exercises this option.

Resource protection. The community spouse may retain a Community Spouse Resource Allowance (CSRA) within annually adjusted federal limits. The actual amount is based on a "snapshot" of the couple's resources at the first day of continuous institutional or HCBS-equivalent service of at least 30 days. Contact DCH or an elder law attorney for current year figures. The home is exempt while the community spouse lives there; one car is exempt; household goods and personal effects are exempt; $1,500 in burial space and burial funds per person is exempt.

Income protection. The community spouse keeps her or his own income entirely. If the community spouse's income is below the Minimum Monthly Maintenance Needs Allowance (MMMNA), the institutional or waiver spouse may "shift" income to the community spouse up to the MMMNA, with an excess shelter allowance potentially increasing the cap. Contact DCH or an elder law attorney for current year figures.

Practical application in Georgia. Section 1924 applies to applicants for institutional Medicaid (nursing facility) AND for CCSP, SOURCE LTSS components, NOW, COMP, ICWP, and other HCBS waivers. The DHS DFCS eligibility worker conducts the snapshot, calculates the CSRA, and applies the income allowance.

Planning considerations. Couples often work with elder law counsel to plan for spousal impoverishment, especially in advance of expected need. Medicaid-compliant annuities (irrevocable, actuarially sound, naming the state as primary remainder beneficiary up to amounts paid), special needs trusts, and outright spend-down on exempt resources are common planning techniques. The Medicaid 60-month look-back applies to transfers; uncompensated transfers within the look-back trigger a transfer penalty period of ineligibility.

Money Follows the Person

Money Follows the Person (MFP) is a federal grant program supporting transitions from nursing facilities, hospitals, and ICF/IIDs to the community. Originally enacted in the Deficit Reduction Act 2005, MFP has been extended several times by subsequent legislation.

How MFP works. An eligible individual must have lived in a qualified institution for a minimum period and meet Medicaid eligibility. MFP provides:

• Transition coordination
• Transition services for housing deposit, utilities, and household goods
• Enhanced FMAP (federal match boost) for the first year of community services
• Access to HCBS waiver slots (Georgia prioritizes MFP transitions)

Georgia MFP. Operated through DBHDD (for I/DD transitions from ICF/IIDs and state hospitals) and DCH (for aged/disabled transitions from nursing facilities). Funded transitions have totaled in the thousands over the program's history. The Olmstead Settlement Agreement specifically referenced MFP for I/DD transitions.

Electronic Visit Verification

Section 12006 of the 21st Century Cures Act 2016 required all states to implement Electronic Visit Verification (EVV) for Medicaid-funded personal care services and home health services.

What EVV captures.

• Type of service provided
• Individual receiving service
• Date of service
• Location of service
• Individual providing service
• Time service begins and ends

How it works in Georgia. Georgia uses HHA Exchange and Tellus as primary EVV vendors (varies by waiver and provider). Caregivers check in and out via mobile app, telephone IVR, or fixed device at the service location. Provider agencies use this data for billing; claims without EVV data are rejected.

Common issues. Missed check-ins or check-outs can cause claim denial. Members are not financially liable; provider must resolve. Family caregiver workforce challenges with EVV adoption have driven some attrition.

Penalty for non-compliance. Federal Medicaid Assistance Percentage (FMAP) reduction for states that fail to implement EVV. Georgia is in compliance.

Worked example: Eleanor, age 78, Macon, CCSP enrollment after husband's death

Eleanor is 78 years old, recently widowed, and lives alone in her Macon home. Her mobility is limited (she uses a walker), she has early-stage dementia, and she needs prompting and physical assistance with bathing, dressing, and meal preparation. Her daughter Maria lives in Atlanta, calls weekly, and visits monthly, but cannot move Eleanor in or provide daily care.

Eleanor's income is $1,100 per month in Social Security survivor benefits (about 73 percent FPL). Her resources are $1,800 in savings (under the $2,000 ABD Medicaid limit). She is approved for full ABD Medicaid in Georgia.

Maria calls the ADRC at 1-866-552-4464 to ask about home-based services for Eleanor. The ADRC connects her to the Area Agency on Aging serving Bibb County (Middle Georgia AAA). The intake worker schedules a DON-R functional assessment at Eleanor's home.

The assessment shows multiple ADL deficits (bathing, dressing, transferring) plus cognitive impairment requiring supervision. Eleanor scores in the nursing-home-level-of-care range. The intake worker confirms CCSP eligibility.

A CCSP slot is available within four weeks (Middle Georgia AAA has no significant backlog at this time). The care coordinator meets with Eleanor and Maria to develop a person-centered service plan:

• Personal Support Services (PSS) 20 hours per week: a personal support worker comes twice daily, mornings (bathing, dressing, breakfast) and evenings (dinner, evening routine)
• Adult Day Health 2 days per week at a Macon community center
• Personal Emergency Response System (a wearable button)
• Home-Delivered Meals 5 days per week

Eleanor's coverage:

• Medicare for medical care (PCP, hospital, specialists)
• Medicaid as secondary for Medicare cost-sharing (QMB+ since she's also full Medicaid)
• CCSP for the LTSS components above

The state's annual cost for Eleanor's CCSP services is a fraction of what nursing-facility placement would cost, while keeping her at home and giving Maria peace of mind.

Worked example: Marcus, age 45, Albany, ICWP after multiple sclerosis diagnosis

Marcus is 45 and lives in Albany. He was diagnosed with multiple sclerosis at age 39, and his disability has progressed: he now uses a power wheelchair, needs help with transfers (bed to chair, toilet), and cannot bathe independently. He left full-time employment four years ago and now does occasional remote consulting.

His income is a modest monthly SSDI amount that places him above the ABD income standard. His resources are $4,000 in savings, which exceeds the $2,000 ABD Medicaid limit.

Step 1: Achieving Medicaid eligibility. Marcus initially applied for ABD Medicaid and was denied because both his income exceeded the ABD income standard AND his resources ($4,000) exceeded $2,000. He spent down his resources to $2,000 by paying off a medical bill and a credit card balance. He re-applied with documented spend-down, but income was still over. His DFCS worker explained the medically needy spend-down pathway: he can incur medical expenses to bring his countable income below the medically needy threshold each month, then use Medicaid for the rest. Alternatively, he could explore the Medicaid Buy-In for Working People with Disabilities. After reviewing options, the worker also noted that ICWP and CCSP applicants can use the institutional income standard (300 percent of the SSI Federal Benefit Rate) with patient liability. Marcus's income is well under the institutional standard. He is approved under the institutional eligibility pathway specifically for ICWP application.

Step 2: ICWP application. Marcus calls the ADRC at 1-866-552-4464; he is referred to the ICWP contracted case management entity. The case manager schedules a comprehensive assessment. Marcus meets NHLOC criteria (multiple ADL dependencies, transfer dependence, requires significant physical assistance).

Step 3: Waiting list. ICWP has a waiting list. Marcus is placed; the case manager estimates a 6-month wait. During the wait, Marcus uses:

• Limited Medicaid State Plan personal care (narrow scope, maybe 5-10 hours per week)
• Medicare home health agency for skilled nursing/therapy (intermittent, episodic)
• Family support
• A privately-paid attendant 10 hours per week

Step 4: Enrollment. Six months later, an ICWP slot opens. The case manager develops the service plan:

• Personal Support Services 30 hours per week (morning and afternoon shifts)
• Adult Day Health 3 days per week at an Albany community center
• Personal Emergency Response System
• Specialized medical equipment: shower chair, lift, accessible van transportation

Outcome. Marcus avoids nursing facility placement. He continues his part-time consulting (income permitted within ABD/institutional standards). He maintains independence and quality of life.

Worked example: Jamil, age 7, Columbus, NOW waiver for autism with intellectual disability

Jamil is 7 years old and lives in Columbus with his parents and two siblings. He was diagnosed with autism spectrum disorder at age 3 and intellectual disability (IQ in 50s) at age 5. He is verbal but with significant language delays, needs intensive support with self-care, has sensory sensitivities, and exhibits some self-injurious behavior under stress.

His parents both work full-time; combined family income is $48,000 per year. They have employer-sponsored health insurance that covers his medical care but does not cover the intensive ABA therapy and behavioral supports he needs.

Step 1: Medicaid eligibility through Katie Beckett. The family income of $48,000 exceeds the regular Medicaid eligibility threshold. But Jamil meets ICF/IID level of care (significant adaptive functioning deficits in multiple domains, requires intensive supervision). The family applies through the DCH Katie Beckett TEFRA pathway. Jamil's own income is zero; his resources are zero. Katie Beckett approved; Jamil now has Medicaid for medical care, therapies (PT, OT, speech via EPSDT), and behavioral health services.

Step 2: NOW waiver application. The family calls DBHDD Intake at 1-888-273-1414. The intake worker schedules an intake assessment. Jamil's ICF/IID LOC is confirmed.

Step 3: Waiting list. Jamil is placed on the combined NOW/COMP waiting list. Without crisis prioritization (Jamil is not at imminent risk of institutionalization given parental care), he may wait many years for a slot.

Step 4: Coping during the wait. The family uses:

• Medicaid State Plan EPSDT for medically-necessary therapies (PT, OT, speech)
• ABA therapy (now Medicaid-covered under EPSDT for children with autism since 2020 policy update)
• School-based special education services
• Out-of-pocket parent respite (occasional)
• Advocacy through Georgia Council on Developmental Disabilities (1-888-275-4233)
• Disability Rights Georgia (404-885-1234) for legal questions about access to services

Step 5: Future planning. As Jamil ages toward age 18, the family revisits NOW/COMP status. If wait continues, the family may explore other options (private services, residential placement if needs increase). Crisis prioritization may apply if his behaviors escalate or family caregiving capacity diminishes.

Worked example: Diana, age 82, rural Dougherty County, SOURCE case management post-hospitalization

Diana is 82 and a full-benefit dual eligible (QMB plus full Medicaid). She lives alone in Albany. After a fall in her bathroom, she fractures her hip and is hospitalized at Phoebe Putney. Surgery is successful but she will need significant rehabilitation and home support.

The hospital discharge planner contacts SOURCE care coordinator (Region 10 SOURCE contractor). The SOURCE coordinator visits Diana in the hospital and conducts a discharge planning assessment:

• Medicare home health agency for skilled nursing and PT/OT (intermittent)
• Medicare DME for hospital bed, walker, raised toilet seat (covered)
• Medicaid for personal care needs beyond Medicare-covered skilled care
• CCSP referral initiated concurrent with hospital discharge

Because CCSP gives post-acute hospital discharge applicants priority, a slot opens within two weeks. Person-centered service plan:

• Personal Support Services 30 hours per week (high-intensity during recovery, scaling down as Diana regains function)
• Adult Day Health 2 days per week (starts after she's medically stable)
• Personal Emergency Response System
• Home-Delivered Meals

The SOURCE coordinator continues care coordination across Medicare (PCP, specialists, home health agency) and Medicaid (CCSP services). When Diana's Medicare home health episode ends (typically 60 days), the SOURCE coordinator ensures continuity through CCSP.

Outcome. Diana returns home from hospital with coordinated services. SOURCE prevents fragmentation that would otherwise occur between Medicare and Medicaid. CCSP provides the LTSS that Medicare doesn't cover.

Worked example: Aisha, age 28, Savannah, COMP waiver after caregiver health decline

Aisha is 28 and has Down syndrome with significant cognitive disability (IQ in 40s), a seizure disorder requiring daily medication and periodic adjustment, and gastrointestinal issues requiring specialized diet and feeding support. She has lived with her mother Maria (62) all her life.

Maria has provided primary care for Aisha for 28 years. Recently, Maria was diagnosed with congestive heart failure and significant arthritis; she can no longer provide the 24-hour supervision Aisha requires.

Step 1: Apply for NOW/COMP. Family calls DBHDD Intake at 1-888-273-1414. Intake assessment shows Aisha's needs are intensive: 24-hour supervision, behavioral supports during stress, skilled nursing assessment for medication management, complex GI care. Her needs exceed the NOW cost cap. She is designated for COMP rather than NOW.

Step 2: Crisis prioritization. Aisha is placed on the NOW/COMP waiting list with crisis priority due to caregiver health decline. The family documents Maria's medical condition through letters from her physician.

Step 3: Slot opens. A COMP slot opens substantially faster than the standard multi-year wait because of crisis priority.

Step 4: Service plan. Person-centered plan developed with Aisha, Maria, and DBHDD support coordinator:

• Community Residential Alternative (CRA): small group home with 4 residents, 24/7 staffing
• Day Program: 5 days per week community-based
• Supported Employment: explore job possibilities in food service or retail
• Behavioral Supports: behavior specialist consultation
• Skilled Nursing: medication management, seizure protocol oversight
• Transportation: to/from day program

Step 5: Transition. Aisha gradually transitions to the CRA over 6 weeks (short visits, then overnight stays, then full move). Maria participates throughout. After transition, Maria visits frequently and Aisha comes home for holidays.

Outcome. Aisha gains independence and community engagement. Maria's caregiving burden is relieved and she focuses on her own health. The state has facilitated Aisha's transition while honoring Olmstead's community-integration mandate.

Worked example: Tasha's mother, age 76, Atlanta, Olmstead-grounded nursing-home diversion via CCSP

Tasha's mother Carol, 76, lives in Atlanta. She has had a stroke with significant left-side weakness, aphasia (difficulty speaking and understanding), and cognitive changes. She is hospitalized at Emory Atlanta. The hospital discharge planner recommends nursing facility placement for short-term rehab and notes that, given her impairments, longer-term institutional placement may be appropriate.

Tasha (33) and her father (Carol's husband, 78) want Carol home. They contact ADRC at 1-866-552-4464 to explore options.

Olmstead obligation. Under Olmstead v. L.C. and the 2010 Georgia USDOJ Settlement, the state has an obligation to seriously consider community alternatives before placing someone in a nursing facility. The discharge planner must engage in this analysis.

ADRC arranges a rapid in-hospital assessment by a CCSP care coordinator. NHLOC criteria are met (multiple ADL dependencies, transfer dependence, cognitive impairment requiring supervision).

CCSP rapid enrollment. Because Carol is in hospital and is being considered for nursing facility placement, she receives post-acute priority. A CCSP slot opens within one week.

Service plan.

• Personal Support Services 40 hours per week (high-intensity initially)
• Adult Day Health 4 days per week (at a center near Tasha's father)
• Skilled Nursing for medication management
• Home-Delivered Meals
• Specialized Medical Equipment: hospital bed, lift, accessible bathroom modifications (some via SNF rehab visit, some via DME)
• Section 1924 spousal impoverishment: Carol's institutional income standard applies; Tasha's father retains the Community Spouse Resource Allowance and Monthly Maintenance Needs Allowance

Outcome. Carol is discharged home with intensive CCSP services and Medicare home health for the skilled rehabilitation phase. Nursing facility placement is avoided. Tasha and her father provide informal support around the formal services. Carol regains some function over the following six months. Quality of life maintained at home.

Practical guidance for families navigating Georgia Medicaid HCBS waivers

Start with the right intake number.

• CCSP, SOURCE, ICWP: ADRC at 1-866-552-4464
• NOW or COMP: DBHDD Intake at 1-888-273-1414
• GAPP / Katie Beckett: DCH (Member Services 1-866-211-0950 for referral)
• Olmstead Hotline (risk of unnecessary institutionalization): 1-844-292-1531

Gather documentation in advance. Functional assessments are easier when families bring: a list of activities of daily living the person needs help with; a list of medications; a list of medical conditions and recent hospitalizations; a list of current providers (PCP, specialists, therapists); a description of behavioral needs if applicable; family caregiving status and what supports already exist.

Apply early, even for the waiting list. Wait times can be long. The earliest you can be placed on the list, the better. If your situation is genuinely emergent or imminent crisis, request crisis prioritization with documentation.

Use Section 1924 spousal impoverishment if you're married. Don't spend down a healthy community spouse to poverty. Section 1924 protects significant resources and a monthly income allowance within federally set limits; contact DCH or an elder law attorney for current figures.

Explore Katie Beckett TEFRA for children. If your child has a disability and your family income is above the regular Medicaid limit, Katie Beckett may be the pathway. Eligibility based on the child's own income, not the parents'.

Person-centered planning matters. When the service plan is developed, your voice and the participant's voice should drive it. Choose providers. Specify what services are needed when. Identify goals. Revisit annually.

Appeal if you're denied or your services are reduced. Notice of denial, reduction, or termination must come at least 10 days in advance. File an appeal within 90 days. Aid pending (services continue during the appeal) is available if you file within 10 days of the notice. Office of State Administrative Hearings (OSAH) hears the case. Free legal help: Georgia Legal Services 1-833-457-7529, Atlanta Legal Aid 404-377-0701, Disability Rights Georgia 404-885-1234.

Report quality concerns. If a provider is unsafe or abusive, report to Adult Protective Services (1-866-552-4464) for adults or Division of Family and Children Services for children. Long-Term Care Ombudsman 1-866-552-4464 can advocate on behalf of waiver participants.

Reach out to brevy.com for personalized eldercare guidance. Brevy helps families navigate HCBS waivers, dual eligibility, and long-term care planning across Georgia.

FAQ

A few more common questions Georgia families ask:

My adult child has Down syndrome. What waiver? NOW (New Options Waiver) or COMP (Comprehensive Supports Waiver Program), administered by the Department of Behavioral Health and Developmental Disabilities (DBHDD). NOW serves adults with intellectual/developmental disabilities needing less intensive supports (with a per-participant cost cap). COMP serves adults needing more intensive supports (24/7 care, behavioral supports, skilled nursing). Call DBHDD Intake at 1-888-273-1414.

My spouse needs nursing-home-level care, but I want to keep our house. How does spousal impoverishment work? Section 1924 of the Social Security Act, the spousal impoverishment provisions, protects the community spouse. Georgia applies §1924 to both nursing facility applicants and HCBS waiver applicants. Within federally set limits, the community spouse may keep a significant portion of countable resources and a monthly income allowance. Your home is exempt while you live there. Your car is exempt. Contact DCH or an elder law attorney for current year figures. Elder law counsel is generally recommended for spousal-impoverishment planning, particularly around annuities and the five-year look-back for transfers.

What is the Olmstead Hotline and when should I call it? The Georgia Olmstead Hotline, 1-844-292-1531, is for individuals at risk of unnecessary institutionalization or for individuals already in institutions who want to transition to the community. Olmstead v. L.C. (1999) and the 2010 USDOJ Settlement Agreement require Georgia to seriously consider community alternatives before institutionalization. The hotline connects to ADRC and DBHDD for the relevant waiver pathway.

Can I direct my own services? For some waivers, yes, through self-directed personal assistance (Section 1915(j)). Participants can manage their own personal care budget within plan parameters, hire their own attendants (including some family members in specific circumstances), and direct services. Talk to your care coordinator about self-direction options in your waiver.

What is Money Follows the Person? Money Follows the Person (MFP) is a federal grant program that helps Medicaid beneficiaries transition from institutions (nursing facilities, ICF/IIDs, state hospitals) to the community. It provides transition coordination, transition services (housing deposit, utilities, household goods), and enhanced FMAP for an initial period of community services. MFP has been extended by subsequent legislation. In Georgia, MFP is administered through DBHDD (for I/DD) and DCH (for aged/disabled).

What is Electronic Visit Verification (EVV) and why does my caregiver need to use it? EVV is a federal requirement under Section 12006 of the 21st Century Cures Act for Medicaid-funded personal care services and home health services. EVV captures the date, time, location, service type, and parties involved in each visit. Georgia uses HHA Exchange and Tellus as EVV vendors. Your caregiver checks in and out via mobile app or telephone. If a check-in is missed, the provider must remediate; your services are not interrupted, but the provider may face billing issues.

Are HCBS waiver settings required to be community-integrated? Yes, under the CMS HCBS Settings Final Rule (42 CFR 441.301(c)(4)). Settings must be community-integrated, individually chosen, and respect privacy/dignity/autonomy. Provider-owned residential settings must offer leases, privacy in living units, food access at any time, visitor rights, and freedom to control daily schedule. Settings presumed institutional (on grounds of an institutional facility, etc.) face heightened scrutiny.

Can I get a waiver if I'm a dual eligible (Medicare + Medicaid)? Yes. Dual eligibles can enroll in CCSP, SOURCE, NOW, COMP, ICWP, or any other Georgia HCBS waiver if they meet the waiver's eligibility criteria. Medicare covers medical care; Medicaid (including the waiver) covers LTSS. SOURCE is particularly useful for duals because it coordinates Medicare and Medicaid.

Where can I get free help applying? Free intake and counseling resources include ADRC at 1-866-552-4464 (CCSP, SOURCE, ICWP); DBHDD Intake at 1-888-273-1414 (NOW, COMP); DCH Member Services at 1-866-211-0950; GeorgiaCares SHIP at 1-866-552-4464 (Medicare and dual coverage); Long-Term Care Ombudsman at 1-866-552-4464; and Disability Rights Georgia at 404-885-1234. For legal questions and appeals, Georgia Legal Services 1-833-457-7529, Atlanta Legal Aid 404-377-0701, Georgia Advocacy Office 1-800-537-2329.

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