Part One: The Functional Needs Assessment Tool
By Larry Deal, Independence Northwest Executive Director

Customers, Families, Providers and Community Members,

As you might have heard, there’s a series of significant changes happening in services for adults with intellectual and developmental disabilities here in Oregon. This is the first of several short(ish) articles to update you on changes to your services and to solicit your feedback, thoughts, and concerns. Let’s start with an explanation of why some of the changes are happening.

Why Are Things Changing?

In short, the Oregon Department of Human Services (the state) gets money from the federal government (about 60% of service dollars) and during a recent review by CMS (Centers for Medicare and Medicaid Services), Oregon was found deficient in several areas. As a result, the feds are demanding a series of changes on a short timeline. At this point, CMS has submitted its findings only for Oregon’s comprehensive (24/7) services; findings from their review of brokerage services are forthcoming.

In addition to the audit findings, Oregon has experienced some budgetary shortfalls, specifically with regard to the program – Aging and People with Disabilities Services – that serves seniors and people with physical disabilities. The Department of Human Services and the Oregon legislature have determined that migrating all services to a new program called the Community First Choice Option (or K Plan) will bring about 6% more federal funds into the state. This means many changes for brokerage customers and providers.

I will address these changes in future articles, but for this piece, let’s focus on one big change that will affect brokerage customers in the very near future: CMS’s mandate that Oregon create and implement a Functional Needs Assessment tool to be used on all individuals receiving services paid for by federal funds. For the record, this change isn’t related to the K Plan or the budget, just the CMS review.

Historical Assessment Practices in Brokerage Services

Historically, brokerages have not used extensive formal assessments to determine your service needs and budgets. Everyone has been eligible for just about the same amount of service dollars (around $14,000 per year, give or take.) For the last eleven or so years, when a person has been referred to brokerage services, we sit down and speak with you about your support needs and personal goals. From there, we seek out natural supports and resources in the community to help you achieve those goals. If there’s a need for funded services, we support you to find the right provider, we assist you with hiring/contracting with the provider, and we provide quality support and oversight for the services you receive. We have to prove that you have a disability-related need for every service purchased. We glean support needs through conversations with you and fill out a state document called the Customer Goal Survey. This document, when completed, resides in a customer’s file at the brokerage and is reviewed by the state when they visit for annual audits.

Starting this fall, things will change. In addition to our usual practices, we will begin completing a Functional Needs Assessment on each and every brokerage customer, new or old. The FNA must be administered annually and will usually take place before we complete your annual ISP (Individual Support Plan.)

The state recently released a transmittal explaining expectations and timelines for implementation.

So, What is a Functional Needs Assessment?

Oregon’s Functional Needs Assessment (FNA) is a scored tool that asks for in-depth information on your support needs in the following areas:

  • Mobility
  • Transferring
  • Positioning
  • Eating/Drinking
  • Toileting
  • Bladder Control
  • Urinary Catheter Care
  • Bowel Control
  • Hygiene (Menses, Bathing, Dressing and General Care)
  • Housekeeping
  • Meal Preparation
  • Shopping
  • Transportation
  • Money Management
  • Communication (Expressive and Receptive)
  • Personal Safety
  • Fire/Emergency Evacuation
  • Medication Management
  • Health Management Supports
  • Complex Health Management Supports
  • Equipment
  • Behavioral Supports (Supervision and Interventions)
  • Legally Mandated Supervision
  • Nighttime Needs

The FNA, based on locally utilized tools as well as materials from other states,   has been developed primarily by state employees, with input and review by stakeholders from a variety of backgrounds, including brokerages. The FNA was created in Excel spreadsheet format so that scores will automatically calculate when the questions are answered on the document. However, the state has not yet completed the algorithms and formulas that will determine the services brokerage customers will be eligible to receive. They have recently brought on an outside contractor to complete the project.

Once the state finishes building the FNA, your Personal Agent will be responsible for administering the tool and assigning values for each question answered. Since the tool is still incomplete, we have not yet seen how someone’s needs will equate to actual services, but expect to soon.  The current estimate for a fully functional tool is October 1st, 2013.

Will This Affect Individual Funding?


As mentioned earlier, the historical practice has been to offer you a set sum of service dollars (on average $14,000 a year.) If brokerage services were inadequate to meet your needs, crisis services and comprehensive services (group home, foster home, etc.) were offered as an option.

The Functional Needs Assessment tool will not have a dollar amount attached. Instead, it will determine how many units of most services you will be eligible for. The FNA will determine what you have access to, based on your disability-related needs.  For example, it may say you are eligible for 100 hours of respite per year, 350 hours of skills training and it will suggest appropriate resources to build a ramp on your home for safety and access. Those pre-determined resources are then utilized to bring on providers and build the plan of care.

Additionally, your benefit level will no longer be capped. The services a person is eligible to receive will be wholly individualized. Although no one can be sure of precisely what the results of the new model will be, the state expects that some people will be eligible for more services than they currently receive and some people will be found eligible for fewer services than they currently receive.

Can Changes Be Made to the Tool?


This isn’t the first tool the state has created. The SNAP tool (used to set rates for providers in foster care) is now on iterations into the double digits. There are likely to be many revisions to the FNA over the first couple of years as the state fine-tunes and hones it through feedback and inquiry.

The state will be receiving copies of all completed assessments conducted on customers. You or your legal representatives may request a copy of the FNA tool at any time. The Department will be sharing when there are major changes to the tool, but state representatives have stated that the state will not be releasing information related to the scoring algorithms and may or may not share when the algorithms have been changed. There is currently an advisory group comprising stakeholders from a variety of backgrounds who will continue meeting well into the future.

You always have the right to request a new review of the assessment; brokerages are responsible for performing the assessment within 45 days of request. Higher level review details are forthcoming.

Want to Learn More?

Information changes, literally, by the hour. Oregon’s DD services have never seen such sweeping change so swiftly. Portions of this article might be out-dated within a day or two, in fact. If there are significant changes or amendments, I will note them below this article on Independence Northwest’s blog.

To help customers, families and their advocates better understand what’s happening, Independence Northwest will begin hosting a series of informational sessions at our office a couple of times a month. The sessions will cover information on the Functional Needs Assessment as well as other changes.

Scheduled Sessions:

When:         Wednesday August 21st 6:30 – 8:00pm

                     Wednesday August 28th 6:30 – 8:00pm

Where:        541 NE 20th Avenue Suite 103, Portland

Please RSVP by calling Rachel Kroll at INW (503.546.2950) so we are sure we have ample materials and space for the presentations.

Keep an eye out for additional articles in the coming days and weeks on the K Plan, changes to guardian payment, changes to case management options, changes to the brokerage ISP (Individual Support Plan) and more.


If you have questions, please don’t hesitate to contact your Personal Agent for the latest details. You may also drop me a line at and I’ll do my best to either answer your question or refer you to someone who can.

Changes to services come with some degree of difficulty and we recognize that some of these changes are significant. We will do all we can to share the information we receive and offer transparency and support through each transition.

Thank you for being part of the Independence Northwest and the brokerage community. We are honored to serve you.

Additional Resources