his reduction in hours (Faatoafe Decl. ¶ 19). Instead, he will likely have to resort to the inferior bath,” which creates a high risk of infection. (Id.) Further, Z.J.’s bowel program (inducing “bed his bowels with a suppository, then cleansing Z.J. following the bowel movement) will be delayed every morning because the personal care attendants cannot arrive as early due to the reductions. (Id. ¶¶ 12b, 20.) This change in his care routine places Z.J. at risk of infection, hospitalization and even death. (Id. ¶ 20.) Z.J.’s personal care attendant, Glenda Faatoafe, has been providing Z.J.’s care for five years (id. ¶ 2), and she believes the reduced hours will result in a gap of care” and a risk of deteriorating [health]” (id. ¶ 16). Victoria “concerning “serious Partridge, who has provided personal care assistance for A.B., An.B., J.B. and M.B. over the past eight years, will have to make impossible choices between tasks such as taking A.B., M.B. and J.B. to medical appointments, doing laundry after toileting incidents, cooking and bathing. (Partridge Decl. ¶ 13.) Ms. Partridge fears that the reduced hours will force A.B., An.B., J.B. and M.B. into nursing homes. (Id. ¶¶ 5, 27.) For those receiving additional hours through the Exception to the Rule (ETR) process, the harm associated with reducing their services is undeniable. The State has already made a specific determination that they require more hours than those generated by CARE for “the client’s welfare” and were thus approved for additional hours. Wash. Admin. Code § Irrespective of the determination that the additional hours were needed for the individuals’ welfare, the State has nevertheless reduced the total hours of in-home personal care to individuals with ETRs. (HCS Management Bulletin, DKT 66, Ex. 10, at 2, Dec. 2, 2010 (“Clients who have ETRs in place for personal care will have the reduction applied to their CARE generated hours, but not the additional hours approved by ETR.”).) As a result, the
his reduction in hours (Faatoafe Decl. ¶ 19). Instead, he will likely have to resort to the inferior “bed bath,” which creates a high risk of infection. (Id.) Further, Z.J.’s bowel program (inducing his bowels with a suppository, then cleansing Z.J. following the bowel movement) will be delayed every morning because the personal care attendants cannot arrive as early due to the reductions. (Id. ¶¶ 12b, 20.) This change in his care routine places Z.J. at risk of infection, hospitalization and even death. (Id. ¶ 20.) Z.J.’s personal care attendant, Glenda Faatoafe, has been providing Z.J.’s care for five years (id. ¶ 2), and she believes the reduced hours will result in a “concerning gap of care” and a “serious risk of deteriorating [health]” (id. ¶ 16). Victoria Partridge, who has provided personal care assistance for A.B., An.B., J.B. and M.B. over the past eight years, will have to make impossible choices between tasks such as taking A.B., M.B. and J.B. to medical appointments, doing laundry after toileting incidents, cooking and bathing. (Partridge Decl. ¶ 13.) Ms. Partridge fears that the reduced hours will force A.B., An.B., J.B. and M.B. into nursing homes. (Id. ¶¶ 5, 27.) For those receiving additional hours through the Exception to the Rule (ETR) process, the harm associated with reducing their services is undeniable. The State has already made a specific determination that they require more hours than those generated by CARE for “the client’s welfare” and were thus approved for additional hours. Wash. Admin. Code § Irrespective of the determination that the additional hours were needed for the individuals’ welfare, the State has nevertheless reduced the total hours of in-home personal care to individuals with ETRs. (HCS Management Bulletin, DKT 66, Ex. 10, at 2, Dec. 2, 2010 (“Clients who have ETRs in place for personal care will have the reduction applied to their CARE generated hours, but not the additional hours approved by ETR.”).) As a result, the
mrvdreyfus_soi.docx