Georgia Medicaid NOW and COMP Waivers (2026): Eligibility, Planning List, Services

::hero{eyebrow="Georgia Medicaid" headline="Georgia Medicaid NOW and COMP Waivers" subhead="How Georgia's two Section 1915(c) HCBS waivers serve Georgians with intellectual and developmental disabilities, how the Planning List manages families waiting for enrollment, and how the Olmstead Settlement Agreement, the HCBS Settings Rule, and DBHDD's Crisis Process shape the path to community-based supports."} ::

For families with a child or adult with intellectual or developmental disabilities, no Medicaid program is more important than the New Options Waiver (NOW) and the Comprehensive Supports Waiver (COMP). Together, these two Section 1915(c) Home and Community-Based Services waivers serve thousands of Georgians with intellectual disability, autism, cerebral palsy, traumatic brain injury sustained before age 22, and other developmental disabilities. NOW and COMP fund the supports that allow individuals with I/DD to live in their families' homes, in Host Homes, in small Community Residential Alternatives (group homes serving 2-4 people), or in their own apartments, rather than in institutional Intermediate Care Facilities for Individuals with Intellectual Disability. They fund respite care that gives aging parents a break. They fund Supported Employment that connects adults with disabilities to real work in real workplaces. They fund Behavior Supports that help individuals manage anxiety, sensory regulation, and behavioral health challenges. They fund the Community Living Supports that allow individuals to participate in their communities rather than be segregated.

NOW and COMP are also the Medicaid programs with the longest waiting list in Georgia. Thousands of Georgians are on the Planning List, the formal queue for waiver enrollment maintained by the Department of Behavioral Health and Developmental Disabilities. Some families wait two years for placement. Some wait five years or more. The Planning List operates under priority categories (short-term, medium-term, long-term) and is supplemented by a Crisis Status process that allows individuals at imminent risk of homelessness, caregiver death, abuse, or major behavioral or medical crisis to bypass the standard queue.

This guide explains the federal Section 1915(c) HCBS waiver authority codified at 42 USC 1396n(c), the 1999 Supreme Court decision in Olmstead v. L.C. that anchored the community integration mandate under Title II of the Americans with Disabilities Act, the 2010 Settlement Agreement between the United States and Georgia that reshaped the developmental disability system in this state, the HCBS Settings Rule adopted by CMS, the eligibility criteria for NOW and COMP, the differences between the two waivers, the services covered, the Planning List process, the Crisis Status bypass, the Self-Direction option, and the role of the Support Coordinator. Six worked examples illustrate how the rules apply to real Georgia families. A frequently asked questions section addresses the most common questions families ask. A contact directory provides the phone numbers needed to navigate the system.

::callout{title="Key takeaways"}

• NOW (New Options Waiver) provides lower-intensity supports for adults with I/DD who do not need 24-hour care.
• COMP (Comprehensive Supports Waiver) provides higher-intensity supports including residential placements (Host Home, Community Residential Alternatives) for adults who need 24-hour care.
• Both waivers require an I/DD diagnosis with onset before age 22, Medicaid financial eligibility at the 300 percent SSI standard, and Level of Care equivalent to Intermediate Care Facility for Individuals with Intellectual Disability (ICF/IID).
• The Planning List is the formal waiting list maintained by DBHDD, divided into short-term, medium-term, and long-term priority categories.
• Crisis Status bypasses the Planning List for individuals at imminent risk of homelessness, caregiver death or inability, abuse or neglect, or major behavioral or medical crisis.
• The 1999 Supreme Court decision in Olmstead v. L.C. and the 2010 Settlement Agreement in U.S. v. Georgia anchor the community integration mandate that drives NOW and COMP expansion.
• The HCBS Settings Rule requires HCBS settings to be integrated, support full community access, ensure privacy and autonomy, and facilitate choice in services and providers.
• Self-Direction permits individuals and families to direct their own services through DBHDD's Self-Directed Services program, with a fiscal intermediary handling payroll. ::

The federal framework for HCBS waivers

By Brevy Care Team · Last verified May 12, 2026

Section 1915(c) authority

Section 1915(c) of the Social Security Act, codified at 42 USC 1396n(c) and added by the Omnibus Budget Reconciliation Act of 1981, authorizes Medicaid Home and Community-Based Services waivers as alternatives to institutional care. Before 1981, Medicaid paid for institutional care (nursing facilities, hospitals, Intermediate Care Facilities for Individuals with Intellectual Disability) but generally did not pay for community-based long-term services and supports. Section 1915(c) created a waiver mechanism: a state can waive certain Medicaid requirements (statewideness, comparability, income/asset rules for HCBS-only populations) and pay for HCBS instead of institutional care, provided that:

• The state demonstrates that HCBS is cost-neutral relative to the institutional alternative (HCBS per-enrollee cost cannot on average exceed ICF/IID or NF per-enrollee cost).
• The state targets specific populations (in Georgia's NOW and COMP case, adults with intellectual and developmental disabilities).
• The state limits the number of waiver slots through CMS-approved caps.
• The state operates the waiver through person-centered planning and individualized service plans.

The implementing regulations are at 42 CFR 441.300 through 441.310. Waivers are initially approved for five years and renewed thereafter in five-year cycles.

The HCBS Settings Rule of 2014

The HCBS Settings Rule defines the characteristics that HCBS settings must have to qualify for Medicaid HCBS waiver funding. After multiple extensions, the rule has taken full effect. The rule requires that HCBS settings:

• Be integrated in and support full access to the greater community, including opportunities to seek employment in competitive integrated settings, engage in community life, control personal resources, and receive services in the community.
• Be selected by the individual from among setting options.
• Ensure rights to privacy, dignity, respect, and freedom from coercion and restraint.
• Optimize autonomy and independence in making life choices including daily activities, environment, and with whom to interact.
• Facilitate individual choice regarding services and supports, and who provides them.

For provider-owned or provider-controlled residential settings (Community Residential Alternatives, Host Homes, supported living settings), additional requirements apply: legally enforceable lease or residency agreement, lockable doors, freedom to control schedules and activities, access to food at any time, ability to have visitors, physical accessibility.

Georgia's Statewide Transition Plan, approved by CMS, governs implementation in Georgia. Some sheltered workshops and segregated day programs have closed or transitioned to integrated employment models under the Settings Rule and the Workforce Innovation and Opportunity Act of 2014.

Olmstead v. L.C. and community integration

The Supreme Court's 1999 decision in Olmstead v. L.C., 527 U.S. 581, anchors the community integration mandate that has driven NOW and COMP expansion in Georgia since 2010. The case involved Lois Curtis and Elaine Wilson, Georgia plaintiffs with intellectual disability and mental illness who had been institutionalized at Georgia Regional Hospital. They sought transition to community-based services. The Supreme Court held that Title II of the Americans with Disabilities Act (42 USC 12131 et seq.) requires public entities to administer services to individuals with disabilities in the most integrated setting appropriate to their needs.

The Court articulated a three-part test for when community placement is required: the state's treatment professionals determine community placement appropriate, the individual does not oppose community treatment, and the placement can be reasonably accommodated taking into account state resources and the needs of others with disabilities. Olmstead did not require states to terminate institutional care, but it created a strong legal mandate to develop community alternatives.

The 2010 Olmstead Settlement Agreement with Georgia

After a Department of Justice investigation in the mid-2000s finding that Georgia had failed to comply with Olmstead, the United States and the State of Georgia entered into a Settlement Agreement in 2010. The Settlement Agreement required Georgia to:

• Reduce the State Hospital census.
• Expand NOW and COMP enrollment over the term of the agreement.
• Establish 24/7 Mobile Crisis Response services and Crisis Stabilization Units.
• Expand Supported Employment for transition-age youth and adults with I/DD or severe and persistent mental illness.
• Develop Permanent Supportive Housing for adults with severe and persistent mental illness.
• Submit to monitoring by an independent reviewer for the duration of the agreement.

The Settlement Agreement was extended in 2014, again in 2018, and again in subsequent years as compliance milestones were assessed. The independent reviewer publishes annual reports identifying gaps in compliance and progress toward full Olmstead implementation. The agreement remains a central driver of state policy on I/DD and behavioral health services.

ADA Title II and Section 504

The Americans with Disabilities Act of 1990 at Public Law 101-336, Title II, prohibits disability discrimination by public entities, including state Medicaid agencies and state I/DD service systems. Section 504 of the Rehabilitation Act of 1973 prohibits disability discrimination by federally funded entities. Both apply to NOW and COMP administration and to all DBHDD-funded services.

Developmental Disabilities Assistance and Bill of Rights Act of 2000

The DD Act at Public Law 106-402 and 42 USC 15001 et seq. defines developmental disability as a severe chronic disability of an individual that:

• Is attributable to a mental or physical impairment or combination of impairments.
• Is manifested before the age of 22.
• Is likely to continue indefinitely.
• Results in substantial functional limitations in three or more areas of major life activity (self-care, receptive and expressive language, learning, mobility, self-direction, capacity for independent living, economic self-sufficiency).
• Reflects the individual's need for a combination and sequence of special, interdisciplinary, or generic services, individualized supports, or other forms of assistance that are of lifelong or extended duration and are individually planned and coordinated.

This federal definition shapes NOW and COMP eligibility criteria. The DD Act also authorizes State Councils on Developmental Disabilities (Georgia Council on Developmental Disabilities, GCDD), Protection and Advocacy systems (Georgia Advocacy Office), and University Centers for Excellence in Developmental Disabilities (Institute on Human Development and Disability at the University of Georgia).

ICF/IID requirements

The Intermediate Care Facility for Individuals with Intellectual Disability is the institutional alternative to HCBS waivers. ICF/IIDs are regulated under 42 CFR 483.400 through 483.480. Georgia has limited ICF/IID capacity (a few large facilities, most census in private ICF/IIDs), with strong policy preference for community-based placement. The Section 1915(c) cost-neutrality requirement is calculated against ICF/IID per-enrollee cost.

Georgia's framework: DBHDD administration

The Department of Behavioral Health and Developmental Disabilities administers NOW and COMP under interagency agreement with the Department of Community Health. DCH holds the State Plan authority for Medicaid and is the federally designated single state Medicaid agency, but DBHDD operates the day-to-day administration of NOW and COMP, including:

• Intake and eligibility determination (through Georgia Medical Care Foundation, GMCF)
• Planning List management
• Crisis Status review
• Provider enrollment and oversight
• Support Coordinator oversight
• Individual Service Plan approval
• Quality assurance
• Utilization management

DBHDD operates through six Regional Offices: Region 1 (Northwest), Region 2 (Northeast), Region 3 (Atlanta Metro), Region 4 (Southwest), Region 5 (Southeast), and Region 6 (East Central). The Regional Office is the primary contact for waiver enrollment, service authorization, and Support Coordinator assignment.

The statutory framework for DBHDD's authority is at O.C.G.A. §37-2-1 et seq. The historical statute referencing the I/DD population is at O.C.G.A. §37-4, with terminology that has evolved over time. O.C.G.A. §49-4-1 establishes DCH's Medicaid authority. DCH-DBHDD interagency agreements delegate operational responsibility.

The NOW Waiver

Who is eligible

The New Options Waiver is for adults age 18 and older with I/DD who:

• Have an intellectual or developmental disability with onset before age 22, meeting the DD Act definition above. The specific diagnostic criteria include IQ generally below 70 with adaptive behavior deficits, or a diagnosed condition (autism spectrum disorder, cerebral palsy, epilepsy with substantial functional limitations, traumatic brain injury before age 22, others) with substantial functional limitations in three or more major life activity areas.
• Meet Medicaid financial eligibility at the 300 percent SSI standard. The 300 percent SSI standard applies to the individual only; parental income is not counted for adults age 18 and older, which is one of the key reasons waiver enrollment matters for adult children of higher-income families.
• Meet Level of Care equivalent to ICF/IID.
• Are Georgia residents.
• Do not need 24-hour supports (which would qualify them for COMP instead).

Services covered

NOW Waiver services include:

Community Living Supports (CLS): Personal care, supervision, and community engagement in home and community settings. CLS hours are authorized based on individual need within the ISP, ranging from a few hours per week to substantial daily supports for individuals living in family homes. CLS providers are DBHDD-contracted agencies, or under Self-Direction, providers hired directly by the individual or family.

Respite: Short-term relief for unpaid family caregivers. Respite can be provided in the individual's home (in-home respite) or in a residential setting (out-of-home respite). The annual respite hour cap supports occasional breaks for primary caregivers.

Prevocational Services: Skill development in preparation for competitive integrated employment.

Supported Employment: Job coaching, on-the-job supports, follow-along services to help the individual obtain and maintain competitive integrated employment. Includes job development, job placement, on-site coaching, fading of supports as the individual gains skills, and long-term follow-along.

Behavior Supports: Behavior Support Plan development and implementation by qualified behavioral specialists (often Board Certified Behavior Analysts, BCBAs). Covers Functional Behavioral Assessment, plan development, training of natural supports, implementation oversight.

Specialized Medical Equipment: Adaptive equipment beyond standard durable medical equipment, including communication devices (AAC), positioning equipment, and other specialized items.

Environmental Accessibility Adaptations: Home modifications including ramps, grab bars, accessible bathrooms, widened doorways, and other modifications to make the individual's home accessible. Annual caps apply.

Vehicle Adaptations: Modifications to family vehicles or individual vehicles for accessibility (lifts, hand controls, securement systems).

Support Coordination: Independent case management by a qualified Support Coordinator (see below).

Community Access: Group and individual community participation supports.

Natural Support Training: Training for unpaid family members or friends to provide ongoing support.

Annual cost cap

The NOW Waiver annual cost cap varies depending on individual need and DBHDD utilization standards. The cost cap is calibrated to ensure cost-neutrality relative to ICF/IID under Section 1915(c) requirements, while providing adequate services for the lower-need population NOW serves.

Self-Direction option

NOW Waiver participants can choose Self-Directed Services through DBHDD Policy 02-712. Under Self-Direction, the individual or family directs the hiring of providers (typically Community Living Supports providers), determines schedules, and manages day-to-day implementation. A fiscal intermediary contracted by DBHDD handles payroll, taxes, workers' compensation, and the regulatory back-office functions. The individual retains budget authority within the ISP. Self-Direction allows hiring of family members (subject to specific rules) and provides more flexibility than agency-directed care. Self-Direction is underutilized relative to its potential and is a focus area for DBHDD policy expansion.

The COMP Waiver

Who is eligible

The Comprehensive Supports Waiver serves adults with the same I/DD diagnostic criteria as NOW, but who:

• Need 24-hour supports, or
• Live in residential settings (Host Home, Community Residential Alternatives), or
• Have higher-intensity behavioral, medical, or supervision needs.

Services covered

COMP Waiver services include all of the NOW Waiver services plus:

Community Residential Alternatives (CRA): Group homes serving 2 to 4 individuals with 24-hour staff support. CRAs are operated by DBHDD-contracted residential providers. Under the HCBS Settings Rule, CRAs must comply with full community integration requirements including individual lease/residency agreements, lockable doors, freedom to control schedules.

Host Home / Life Sharing: Individual lives in the home of a paid host family. The host family provides 24-hour supports under DBHDD oversight. Host Home is particularly suited to individuals who would not thrive in a larger residential setting but cannot live independently.

Community Living Supports up to 24/7: For individuals living in family homes with high-intensity supervision needs, or in their own apartments with extensive supports.

Supported Living: Semi-independent living with staff support. Individual lives in their own apartment with scheduled staff visits and on-call support.

Intensive Respite: Including more intensive respite for high-need individuals.

Intensive Behavior Supports: Including crisis behavior plans, intensive home-based behavioral interventions, and coordination with crisis stabilization services.

Transportation: To and from waiver services.

Crisis Stabilization: Short-term residential placement during behavioral or medical crises, including coordination with DBHDD's broader crisis system.

Annual cost cap

The COMP Waiver annual cost cap is higher than NOW, depending on individual needs. CRA placements and intensive 24-hour CLS arrangements drive higher costs.

Planning List: how families wait

The structure

The Planning List was formally established by DBHDD in 2013 as the official waiting list for NOW and COMP Waiver enrollment. Thousands of Georgians are on the Planning List. The list is divided into three priority categories:

Short-term: Need within 90 days. Highest priority. Includes individuals approaching crisis, aging-out from foster care or institutional settings with no alternative, families facing imminent disruption.

Medium-term: Need within 6 months. Includes individuals with significant need but who are stable in current setting.

Long-term: Need within 1 year or longer. Lowest priority. Includes individuals with relatively stable family supports who anticipate future need (typically as parents age or as transition-age youth approach adulthood).

Priority categories are reviewed annually and can be revised based on changing circumstances. Annual case reviews allow families to update DBHDD on changes that may affect priority status.

How the queue moves

DBHDD allocates new waiver slots based on legislative appropriations. The Georgia General Assembly approves a specific number of new NOW and COMP slots each fiscal year through the budget process. Once approved, DBHDD allocates slots first to Short-term Planning List, then Medium-term, then Long-term. Within each priority category, allocation considers length of time on the list and specific need factors.

Georgia appropriates new NOW and COMP slots each fiscal year based on legislative appropriations, though the exact numbers fluctuate annually. Advocacy organizations including GCDD have pushed for substantial annual expansion to reduce the Planning List backlog.

Crisis Status: bypassing the queue

Crisis Status allows individuals to bypass the Planning List entirely for imminent need. Crisis Status criteria include:

• Imminent risk of homelessness
• Caregiver death or inability to continue providing care (typically aging parents with health crises)
• Abuse, neglect, or exploitation risk
• Major behavioral crisis or medical crisis requiring intensive supports
• Aging out from foster care or institutional setting with no alternative placement

A family or individual requests Crisis Status through the DBHDD Regional Office or through GMCF. DBHDD reviews documentation including caregiver health records, housing instability evidence, abuse/neglect reports, and clinical evaluations. If approved, the individual moves to expedited waiver enrollment, typically within 60 to 90 days of Crisis Status approval.

Crisis Status is a critical safety valve but is not a substitute for adequate Planning List funding. Many families wait years for Crisis Status because their need does not yet rise to the imminent-risk threshold, even though it is severe.

Service Coordination: the role of the Support Coordinator

When an individual is enrolled in NOW or COMP, DBHDD assigns a Support Coordinator. The Support Coordinator is an independent professional (not employed by a waiver service provider, to ensure conflict-free case management as required by federal HCBS rules). Responsibilities include:

• Conducting person-centered planning with the individual and family.
• Developing the Individual Service Plan (ISP), which specifies the services authorized, the providers chosen, the schedules, the goals, and the outcomes measured.
• Monitoring implementation of the ISP through regular contacts with the individual, family, and providers.
• Reviewing and revising the ISP annually or upon significant change.
• Coordinating with specialty services including medical care, behavioral health, employment, and education.
• Connecting the individual to non-waiver resources including SSI/SSDI, Vocational Rehabilitation, ABLE accounts, and community supports.

The Support Coordinator is the family's primary contact within the waiver system. Building a strong working relationship with the Support Coordinator is one of the most important factors in successful waiver implementation.

Six worked examples

Marcus: NOW Waiver and Supported Employment in Atlanta

Marcus is 24 years old and was diagnosed with autism at age 3. He lived with his mother throughout childhood and adolescence, completing high school through an IEP-supported transition plan. His mother applied for NOW Waiver when Marcus was 19. The family was placed on the Long-term Planning List because Marcus was stable in the family home and his mother was healthy and working full-time.

After three years on the Planning List, a NOW Waiver slot opened. Marcus's Support Coordinator developed an ISP including:

• Community Living Supports 30 hours per week to provide supervision and community engagement while his mother works.
• Supported Employment for placement at a local grocery store, with job coaching for the first 6 months and follow-along support.
• Behavior Supports for occasional sensory regulation challenges.
• Community Access for participation in social activities.

The family chose Self-Direction for CLS, hiring a college student majoring in special education as Marcus's primary CLS provider. The fiscal intermediary handles payroll, and the college student is matched well to Marcus's interests and developmental level. Marcus now works 25 hours per week at the grocery store, has expanded his social network, and continues to live with his mother with the support that the NOW Waiver provides.

Sarah: COMP Waiver via Crisis Status in Macon

Sarah is 32 years old. She has spastic cerebral palsy and intellectual disability and uses a power wheelchair. She lived with her mother as her primary caregiver throughout her adult life. The family had been on the Long-term Planning List for COMP Waiver for 4 years, anticipating future need but with no immediate crisis.

Sarah's mother had a sudden cardiac event and died at age 62. Sarah was left without her primary caregiver. Her brother, who lived in Atlanta and worked full-time, could not provide the 24-hour supports Sarah required.

Sarah's brother contacted DBHDD Regional Office and applied for Crisis Status. With documentation of the caregiver death, Sarah's medical needs (including bowel and bladder management, transfers, feeding assistance), and the absence of alternative supports, DBHDD approved Crisis Status within 30 days.

Within 75 days of Crisis Status approval, Sarah moved into a Host Home with a paid host family who had been trained to support individuals with significant physical disabilities. Her ISP included:

• Host Home placement with 24-hour supports.
• Intensive Behavior Supports for adjustment to the new living situation.
• Transportation to a day program 4 days per week.
• Specialized Medical Equipment including a new power wheelchair and adaptive seating.
• Support Coordination with a Coordinator experienced in physical disability supports.

Sarah remains in the Host Home four years later, with the host family providing stable, loving, family-style supports.

Tyrell: COMP Waiver for aging-out youth in Albany

Tyrell is 19 years old. He was in foster care through the Georgia Division of Family and Children Services from age 8 due to severe family disruption. He has an intellectual disability and ADHD diagnosed during foster care, qualifying for I/DD waiver consideration. Through CHRIS (Comprehensive Child and Family Assessment) services and his high school IEP team, Tyrell was identified as needing waiver supports for his transition to adulthood.

When Tyrell approached 21 (the foster care exit age in Georgia), CHRIS and DFCS coordinated his transition with DBHDD. Under DBHDD's aging-out provisions, Tyrell received expedited COMP Waiver enrollment. His ISP includes:

• Placement in a Community Residential Alternative (CRA) with 2 other young adults and 24-hour staff support.
• Supported Employment continuation from his high school transition planning.
• Community Living Supports oriented toward independent living skills.
• Behavior Supports for transition adjustment.
• Community Access for ongoing social and recreational participation.

Tyrell has now been in the CRA for 18 months. He works part-time at a small business in Albany. He maintains connection with his foster mother, who continues to advocate for him through his Support Coordinator.

Aisha: NOW Waiver and supported employment in Columbus

Aisha is 28 years old. She has Down syndrome and lives with her parents in Columbus. She completed high school through an IEP-supported transition plan and obtained a job at a local hospital working in food service. Her parents applied for NOW Waiver when Aisha was 26, anticipating future transition needs.

After 2 years on the Medium-term Planning List, a NOW Waiver slot opened. Aisha's ISP includes:

• Supported Employment with continued on-the-job coaching at the hospital.
• Community Living Supports 20 hours per week (after-work hours and weekends) for community engagement and supervision.
• Behavior Supports for transition planning as her parents consider their long-term plans.
• Community Access for recreational and social activities.

Aisha's parents are now in their early 60s and are exploring a Host Home transition for Aisha within the next 5 years. Her Support Coordinator is connecting the family to Host Home providers and to GCDD for advocacy support around the eventual transition. The family also opened an ABLE account for Aisha to save for future needs without affecting her Medicaid eligibility.

James: COMP Waiver after TBI in Athens

James is 45 years old. At age 18, he sustained a severe traumatic brain injury in a motorcycle accident. His TBI qualifies as a developmental disability under the DD Act definition because the onset was before age 22, the impairment is substantial and chronic, and it results in functional limitations in multiple major life areas. He lived with his parents throughout his adulthood, receiving extensive supervision and care from them.

By the time his parents reached their 70s, they could no longer provide the level of supervision James needed safely. The family applied for COMP Waiver. After 18 months on the Medium-term Planning List, a COMP slot opened. James was placed in a Community Residential Alternative with 24-hour staff support. His ISP includes:

• CRA placement.
• Intensive Behavior Supports for occasional impulse control challenges associated with his TBI.
• Supported Living elements for skill maintenance.
• Community Access for participation in TBI peer support groups and community recreation.
• Transportation.
• Specialized Medical Equipment for ongoing rehabilitation supports.

James's parents now visit him at the CRA weekly and remain actively involved in his care planning. The CRA placement allows them to age in their own home while knowing James is safely supported.

Diane and David: COMP advocacy in Savannah

David is 22 years old. He has severe intellectual disability, autism, and is nonverbal, communicating through an augmentative and alternative communication device. His mother Diane has advocated for him through Georgia Council on Developmental Disabilities (GCDD) since David was a child. She has served on GCDD task forces, testified at the Georgia General Assembly during budget hearings, and engaged Disability Rights Georgia and All About Developmental Disabilities (AADD) for technical advocacy support.

Diane applied for COMP Waiver for David when he was 18. The family was placed on the Medium-term Planning List. Over the next 2 years, Diane worked with her Support Coordinator and DBHDD Regional Office to document David's increasing needs and the family's projected timeline for needing residential supports. After 2 years, a COMP Waiver slot opened.

David's ISP includes:

• Community Living Supports 24/7 in the family home.
• Intensive Behavior Supports for sensory regulation and communication.
• Respite to give Diane periodic breaks.
• Specialized Medical Equipment including AAC device and adaptive seating.
• Support Coordination with intensive case management.
• Community Access for participation in autism-friendly community programs.

The family is considering Host Home transition planning over the next 5 years as Diane approaches her 60s. Diane continues her advocacy work through GCDD, now mentoring other families navigating the Planning List.

Things commonly missed

Families and individuals navigating NOW and COMP frequently overlook the following points:

1. NOW and COMP are not first-come-first-served: The Planning List uses priority categories based on need, not simply length of time on the list. Length of time matters within each priority category, but Crisis Status and severity drive overall placement.

2. Crisis Status is available: Families facing imminent need (caregiver death, homelessness, abuse, major crisis) can apply for Crisis Status to bypass the Planning List.

3. Planning List does not provide services: Being on the Planning List places you in the queue for future enrollment, not in receipt of services. State Plan Medicaid services (medical care, prescriptions, certain therapies) remain available, but waiver-specific services do not.

4. ICF/IID alternative is available but rare: Georgia has limited ICF/IID capacity and a strong policy preference for community placement. ICF/IID may be an option in specific circumstances but is not a substitute for waiver enrollment.

5. Katie Beckett is a different pathway: Children under 18 with medical fragility or significant disability may qualify for Katie Beckett (TEFRA) coverage, which is separate from NOW/COMP and does not count parental income.

6. 14(c) subminimum wage is phasing out: The Section 14(c) provision of the Fair Labor Standards Act, which allowed subminimum wages for sheltered workshops, is being phased out under WIOA and the HCBS Settings Rule. New competitive integrated employment is the federal policy direction.

7. HCBS Settings Rule reshapes residential: CRAs and Host Homes must comply with full community integration requirements including individual lease/residency agreements, lockable doors, control of schedules, freedom of association.

8. Self-Direction is underutilized: Self-Directed Services empower individuals and families to direct their own care but require active engagement. DBHDD policy supports expanding Self-Direction utilization.

9. Family members can sometimes be paid caregivers: Under specific Self-Direction rules, certain family members can be hired as paid CLS providers. Spouses generally cannot be paid; parents of adult children typically can be paid as CLS providers under Self-Direction.

10. ABLE accounts protect savings: Achieving a Better Life Experience (ABLE) accounts under the ABLE Act of 2014 allow individuals with disabilities to save within annual contribution limits without affecting Medicaid eligibility. Annual contributions and total balances are protected up to specified caps.

11. SSI and SSDI interaction: Most waiver enrollees receive SSI (Supplemental Security Income) or SSDI (Social Security Disability Insurance). SSI eligibility requires income/asset limits; SSDI does not. The 300 percent SSI standard for Medicaid HCBS waivers means most SSI recipients qualify financially for NOW/COMP.

12. Provider choice within network: Waiver participants choose providers from within the DBHDD-contracted provider network. The Support Coordinator helps with provider selection.

13. Crisis Services through GCAL: For behavioral crises, the Georgia Crisis and Access Line (GCAL) at 1-800-715-4225 provides 24/7 mobile crisis response. The 988 Suicide and Crisis Lifeline also routes to GCAL in Georgia.

14. GCDD advocacy is critical: The Georgia Council on Developmental Disabilities at 1-404-657-2126 provides policy advocacy, family support, and systems-level change work. Many families find that engagement with GCDD strengthens their advocacy for their own family member.

15. Disability Rights Georgia and Georgia Advocacy Office: The state's Protection and Advocacy system provides legal advocacy for individuals with disabilities, including waiver enforcement, Olmstead litigation, and individual case advocacy.

16. 1915(i) State Plan HCBS is an alternative not currently used in Georgia for I/DD: Some states use Section 1915(i) State Plan HCBS authority to provide HCBS without a waiver, eliminating the cap on enrollment. Georgia has not adopted 1915(i) for I/DD.

17. Parent to Parent of Georgia at 1-770-451-5484: Provides peer support, navigation help, and family-to-family connection.

18. Vocational Rehabilitation is a parallel system: Georgia Vocational Rehabilitation Agency provides employment supports that can complement Supported Employment in NOW or COMP. Coordinate with VR through the Support Coordinator.

19. Annual ISP review is the family's leverage point: The annual ISP review is the formal opportunity to revise services, adjust hours, add new providers, and document changing needs. Families should prepare carefully for ISP reviews.

20. Appeals are available: NOW/COMP eligibility decisions, service authorization decisions, and Planning List priority placements can be appealed through DBHDD fair hearing procedures and ultimately to DCH and the Georgia Office of State Administrative Hearings.

Frequently asked questions

::accordion{title="Common NOW and COMP Waiver questions"} :::item{question="What is the difference between NOW and COMP?"} NOW (New Options Waiver) provides lower-intensity supports for adults with intellectual or developmental disabilities who do not need 24-hour care. NOW typically supports adults living with family or in independent settings with daily but not around-the-clock supports. COMP (Comprehensive Supports Waiver) provides higher-intensity supports for adults who need 24-hour care, including residential placements such as Host Home and Community Residential Alternatives (small group homes). COMP annual cost caps are higher than NOW. :::

:::item{question="Who is eligible for NOW or COMP?"} Both waivers require: an intellectual or developmental disability with onset before age 22 (meeting the federal DD Act definition); Medicaid financial eligibility at the 300 percent SSI standard (with parental income not counted for adults age 18 and older); Level of Care equivalent to ICF/IID; and Georgia residency. The diagnostic criteria include IQ generally below 70 with adaptive behavior deficits, or a diagnosed condition like autism, cerebral palsy, epilepsy, or traumatic brain injury before age 22 with substantial functional limitations. :::

:::item{question="How do I apply for NOW or COMP?"} Contact Georgia Medical Care Foundation (GMCF) at 1-404-806-3340 to request I/DD waiver intake. GMCF will conduct an initial screening and refer you to DBHDD for Level of Care evaluation. Once eligibility is established, you will be placed on the Planning List in the appropriate priority category based on your current need. :::

:::item{question="What is the Planning List?"} The Planning List is the formal waiting list maintained by DBHDD for NOW and COMP Waiver enrollment. Thousands of Georgians are on the Planning List. The list is divided into three priority categories: short-term (need within 90 days), medium-term (need within 6 months), and long-term (need within 1 year or longer). Priority categories are reviewed annually. Waiver slots are allocated first to short-term, then medium-term, then long-term, with length of time on the list considered within each category. :::

:::item{question="What is Crisis Status?"} Crisis Status bypasses the Planning List for individuals facing imminent need. Criteria include imminent risk of homelessness, caregiver death or inability to continue care, abuse or neglect risk, major behavioral or medical crisis, and aging-out from foster care or institutional setting with no alternative. Crisis Status applications are reviewed by DBHDD Regional Offices with documentation of the imminent need. If approved, the individual moves to expedited enrollment, typically within 60 to 90 days. :::

:::item{question="What services does NOW cover?"} NOW Waiver services include Community Living Supports (personal care, supervision, community engagement), Respite (in-home and out-of-home), Prevocational Services, Supported Employment, Behavior Supports, Specialized Medical Equipment, Environmental Accessibility Adaptations (home modifications), Vehicle Adaptations, Support Coordination, Community Access (group and individual), and Natural Support Training. :::

:::item{question="What services does COMP cover?"} COMP Waiver services include all NOW services plus Community Residential Alternatives (small group homes serving 2 to 4 individuals with 24-hour staff), Host Home / Life Sharing (individual lives with a paid host family), Community Living Supports up to 24/7, Supported Living (semi-independent), more intensive Respite and Behavior Supports, Transportation, and Crisis Stabilization. Annual cost caps are higher than NOW. :::

:::item{question="What is Self-Direction?"} Self-Directed Services through DBHDD Policy 02-712 allow the individual or family to direct the hiring of providers, determine schedules, and manage day-to-day implementation of services. A fiscal intermediary handles payroll, taxes, workers' compensation, and regulatory functions. The individual retains budget authority within the Individual Service Plan. Self-Direction is available in both NOW and COMP. Family members other than spouses can sometimes be paid caregivers under Self-Direction rules. :::

:::item{question="Can my child stay on NOW or COMP after age 18?"} NOW and COMP are adult waivers, generally beginning at age 18. Children with significant medical needs can be served through Katie Beckett (TEFRA) coverage and CCSP/ICWP pediatric pathways before age 18, transitioning to NOW or COMP at adulthood. Transition planning during the high school years is critical to a smooth transition. :::

:::item{question="What is the role of the Support Coordinator?"} The Support Coordinator is an independent professional (not employed by a waiver service provider) who develops the Individual Service Plan, monitors implementation, coordinates with specialty services, and serves as the family's primary contact within the waiver system. The Support Coordinator conducts person-centered planning, reviews and revises the ISP annually, and ensures that services meet the individual's goals and needs. :::

:::item{question="Can I appeal a NOW or COMP decision?"} Yes. Eligibility decisions, service authorization decisions, and Planning List priority placements can be appealed through DBHDD fair hearing procedures, with final administrative appeal to the Georgia Office of State Administrative Hearings. Disability Rights Georgia at 1-404-885-1234 and the Georgia Advocacy Office provide legal advocacy assistance for waiver appeals. :::

:::item{question="What advocacy organizations help families?"} Georgia Council on Developmental Disabilities (GCDD) at 1-404-657-2126 provides policy advocacy and family support. Parent to Parent of Georgia at 1-770-451-5484 provides peer-to-peer family connections. Disability Rights Georgia and Georgia Advocacy Office provide legal advocacy. All About Developmental Disabilities (AADD) provides family support and navigation. The University of Georgia's Institute on Human Development and Disability is the state's University Center for Excellence in Developmental Disabilities under the DD Act. ::: ::

How to navigate NOW and COMP successfully

For families approaching NOW or COMP enrollment, the practical steps are:

1. Start early: Apply for waiver intake as soon as you anticipate need. Even families who do not currently need services should consider waiver application to begin building Planning List time.

2. Contact GMCF: Call 1-404-806-3340 to begin the intake process. GMCF will conduct initial screening and refer to DBHDD.

3. Engage with your DBHDD Regional Office: The Regional Office is the primary point of contact for Planning List management, Crisis Status, and service authorization questions.

4. Connect with advocacy organizations: GCDD, Parent to Parent of Georgia, Disability Rights Georgia, and AADD provide critical navigation and advocacy support.

5. Document needs carefully: Maintain records of caregiver health, behavioral incidents, medical needs, and any factors that may affect priority status. Annual case reviews are opportunities to update priority placement.

6. Plan for transitions: High school transition planning, foster care aging-out, and parents' aging are major transition points that affect waiver need. Plan years in advance when possible.

7. Build a strong relationship with the Support Coordinator: Once enrolled, the Support Coordinator is your primary point of contact. Engage actively in person-centered planning and ISP development.

8. Consider Self-Direction: For families with capacity to manage providers directly, Self-Direction offers flexibility and quality control. Explore Self-Direction through your Support Coordinator.

9. Use ABLE accounts: ABLE accounts allow individuals with disabilities to save within annual contribution limits without affecting Medicaid eligibility. Many banks offer ABLE accounts; Georgia's STABLE Account is one option.

10. Connect to Vocational Rehabilitation and adult employment supports: Supported Employment within the waiver can be enhanced by parallel work with Georgia Vocational Rehabilitation Agency.

11. Maintain engagement with the I/DD community: Self-advocacy organizations like People First of Georgia, family support organizations, and peer networks provide ongoing community and support.

12. Track legislative budget cycles: The Georgia General Assembly approves NOW and COMP slot expansion each fiscal year. Advocacy during the budget process (typically January through April) can affect slot allocations.

Putting it all together

Georgia's NOW and COMP Waivers represent the state's principal Medicaid response to the federal community integration mandate established by Olmstead v. L.C. and operationalized through the 2010 Settlement Agreement with the United States. Together, these two Section 1915(c) HCBS waivers serve thousands of Georgians with intellectual and developmental disabilities, supporting them to live in their own homes, family homes, Host Homes, or small Community Residential Alternatives rather than in Intermediate Care Facilities for Individuals with Intellectual Disability. The waivers fund the Community Living Supports, respite, supported employment, behavior supports, and residential placements that make community integration possible.

The system is not without challenges. The Planning List of Georgians waiting for enrollment is the longest waiver waiting list in the state. Some families wait years for placement, and the Crisis Status safety valve cannot absorb the full pressure. Annual legislative appropriations of new slots have not kept pace with demand, particularly as transition-age youth with I/DD exit the school system and approach adulthood. The HCBS Settings Rule, while a major advance for community integration, has required significant adjustment by residential providers and continues to evolve in implementation. Sheltered workshops and segregated day programs are phasing out, requiring expansion of competitive integrated employment infrastructure.

But the system also represents one of the most substantial state-level commitments to community-based supports for adults with I/DD anywhere in the country. The Settlement Agreement with the United States, the GCDD's policy advocacy, the Protection and Advocacy work of Disability Rights Georgia, and the day-to-day case management of DBHDD's Support Coordinators have built a network of community supports that allows individuals like Marcus, Sarah, Tyrell, Aisha, James, and David to live their adult lives in their communities, with their families, with employment, and with dignity.

For families just beginning this journey, the most important first step is contacting GMCF at 1-404-806-3340 to begin the intake process. The earlier the application, the more time on the Planning List, and the better positioned the individual will be when waiver slots open. For families already navigating the system, engagement with the Support Coordinator, the Regional Office, and the broader advocacy network is the path to making the waiver work effectively for the individual's specific needs and goals. Find personalized help navigating Georgia's NOW and COMP Waivers at brevy.com.

::cta{title="NOW and COMP contacts and resources"} Use the contacts below to apply for NOW or COMP, navigate the Planning List, request Crisis Status, connect with advocacy organizations, and resolve waiver questions.

• GMCF (Georgia Medical Care Foundation) Intake: 1-404-806-3340
• DBHDD Provider Help Desk: 1-404-657-2252
• DBHDD Office of Developmental Disabilities: contact via DBHDD website
• DBHDD Regional Offices (6 regions): dbhdd.georgia.gov
• DCH Medicaid Member Services: 1-866-211-0950
• GCAL Crisis Line: 1-800-715-4225 (988 Suicide and Crisis Lifeline)
• GCDD (Georgia Council on Developmental Disabilities): 1-404-657-2126
• Disability Rights Georgia: 1-404-885-1234
• Georgia Advocacy Office: 1-404-885-1234
• Parent to Parent of Georgia: 1-770-451-5484
• All About Developmental Disabilities (AADD): aadd.org
• Georgia Vocational Rehabilitation Agency: 1-844-367-4872
• Social Security Administration: 1-800-772-1213
• Institute on Human Development and Disability (UGA): University Center for Excellence in DD
• People First of Georgia: self-advocacy network ::

This guide is for general information only and does not constitute medical, legal, or insurance advice. NOW and COMP Waiver policies, eligibility criteria, and Planning List management procedures are subject to change as DBHDD, DCH, the Georgia General Assembly, and CMS update policy. Always confirm current rules with DBHDD and your assigned Support Coordinator. For Crisis Status determinations and behavioral health emergencies, contact your DBHDD Regional Office or GCAL at 1-800-715-4225.