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One DSD · People, Access and Culture
Home and Community-Based Services Policy and Waivers
Sets policy for waiver and community-based services, including eligibility, service menus, rates, and provider standards.
This learning exercise is optional and does not record your responses. Staff remain responsible for using the current DHS Equity Policy and Equity Analysis Toolkit in their work.
Job families based here: Policy and Program Analysis.
Other job families that often help here: Eligibility and Service Delivery, Budgets, Grants, and Contracts, Data, Research, and Quality, Communication and Accessibility.
Explore this work context
Where equity shows up first here 4
A likely pattern, not a description of your specific work — In the Combined Manual this is where BI, CAC, CADI, DD and Elderly Waiver guidance lives, alongside CFSS and the surrounding eligibility, employment and service-option chapters.
Who gets which service mix, and why
Work that sets eligibility rules or service menus tends to raise this first: two people with similar needs can end up with different service mixes, and the reason is not always visible in the record. Usually where step 1 and step 4 do the most work.
The burden of documentation and authorization steps
A requirement that is the same on paper for everyone can still cost some people more time or help to complete than others. Usually step 4 and scan question 4.
The language and format of notices
A notice that is accurate and still unreadable to the person it is for is a common failure point in waiver work. Usually a step 3 and step 6 question.
Provider capacity in different communities
A policy can be neutral and still land unevenly if providers who can deliver it are not evenly available. Usually step 2 (data) — who can actually reach a provider, not only who is technically eligible.
Who else is usually involved
Disability Services Division sits within Aging and Disability Services. DSD is not the DHS Licensing function — HCBS licensing under chapter 245D is DHS Licensing’s decision, separate from MHCP provider enrollment and separate again from the service planning this program sets policy for.
Disability Waiver Program changes
Counties, Tribal Nations, and providers, through the Advisory Task Force on Waiver Reimagine.
The Disability Waiver Rate System
Lead agencies and service providers, through the Rate Management System.
MnCHOICES assessment and support planning
County and Tribal lead agencies, managed care organizations, and Aging and Adult Services.
HCBS licensing versus enrollment
DHS Licensing and MHCP Provider Enrollment — a separate decision from this program's own.
CFSS and the transition from PCA and CSG
Lead agencies, through the CFSS Manual's transition guidance.
Also touches: MnCHOICES assessment and access, Support planning and case management, Olmstead and community integration, Employment and day services.
Data, quality and evaluation, and contracts and fiscal work, share this program's measurement footing rather than its service footing, and usually enter through step 2 rather than step 3.
Something here doesn’t match your work?
This page does not know your unit's current internal teams, working relationships, or who actually holds a given decision day to day — nothing here was guessed to fill that in. Telling the consultant is the single most useful thing you can do with it.
Apply the toolkit
The rest of this page is the same for every program area and job family in the Division.
An equity analysis is the point where equity stops being something we believe and becomes something we decide — done before a decision, it changes the decision; done after, it is paperwork.
Which one do I need: an analysis, or a scan?
Answer these two questions about the work in front of you.
- Has this already been through a full equity analysis — and were those results built into the work?
- Is there genuinely not enough time to do a full analysis?
Yes to either An equity scan is the right instrument. Six questions.
No to both A full equity analysis is the right instrument. Eight steps.
A scan is shorter, not lighter: it keeps every element of the full instrument and adds engagement, evidence, accessibility and accountability criteria of its own.
A Tribal Nation may be affected? Stop here — go to Tribal and Urban Indian Relations. Consultation is government-to-government; a community brief is not that door.
The 8 steps of a full equity analysis
- Desired results and outcomes. What are you changing, what do you want to happen, and who could this land on hardest?
- Data. What do the numbers already show about who is affected? What is missing, and how could you get it?
- Engagement. Who is most affected, who have you actually talked to, and what did they tell you?
- Benefits, burdens, and mitigating unintended consequences. Who gains, who carries extra weight, and how could the plan change to reduce harm?
- Equity impact statement. Pull the findings together in one place.
- Accountability, evaluation, and communication. How will you know if it worked, who is responsible, and who hears back?
- Alignment. How does this fit the equity work already under way?
- Sustainability. Is it funded, staffed and resourced to last — including the data and the engagement?
The 6 questions of an equity scan
- What is the desired outcome? What change do you hope to see?
- Define the impacted communities or groups. Be explicit to race and intersecting identities.
- What can you learn from the data? Use disaggregated data — numbers broken out by group, not one total.
- What are the equity impacts of these actions? Who benefits, who is burdened, and how will you reduce harm?
- How have you used what you learned to confirm or change your design?
- How will you communicate results to impacted communities or groups?
Terms on the real form. Disaggregated data — split by group, not one total. Intersecting identities — a person belongs to more than one group at once. Equity impact statement — the written summary in step 5. Kept in the Department's own words on purpose.
The same questions, five kinds of work
It is the same instrument whether the object is a bill, a policy, a program change, a notice, or a class standard.
A bill
Who is impacted?
A funding formula reads as neutral. Split by county and by race and the reach becomes visible.
A policy
What can you learn from the data?
A documentation rule applies equally; whether people can meet it equally is a different question.
A program change
Who benefits, who is burdened?
Moving a service online lifts a burden for some and sets one down for others.
A public notice
How will you communicate results?
A letter that only works in written English decides who can act on it.
A class standard
What is the desired outcome?
A credential the work does not need narrows the field before hiring begins.
See it done: four versions of one decision
The decision, in all four
A waiver program is considering moving annual reassessments from in-person home visits to video calls.
Numbers below are constructed for teaching and marked illustrative — not DHS figures.
“We don’t have that information yet”
This is a legitimate answer — step 2 asks for it directly: what additional data would be helpful, and how could better data be obtained? Naming a gap is stronger than quietly filling the box.
Write it like this: “We do not have this broken out by race. The lead agency case system holds it. Requested; expected [date]; [name] following up.”
When one group sits inside another
A change can look fine for people with disabilities as a group, and fine for Somali Minnesotans as a group, and still fail Somali Minnesotans with disabilities.
Everyone this Division serves has a disability, so every other difference — language, distance, income, race, age — arrives on top of that one.
- Split the data twice: race and region, language and age.
- If numbers get too small to split, say so — that is a finding.
- Ask who would be missed by every category just used.
Minnesota community briefs can help you ask better questions. They do not tell you what an individual needs.
Your working draft
General terms only — no names, case details, or confidential information. Nothing is saved or sent; it disappears on reload.
Clear everything you have written? This cannot be undone.
Where the real toolkit lives
- DHS Equity Policy
- State of Minnesota Equity Analysis Toolkit — a Quick Guide (through DHS)
- The equity scan (through DHS)
- Explore Minnesota community briefs
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Please leave out case, medical, personnel, complaint, and identifying details anywhere in this program. It is not connected to DHS information systems, does not hold DHS case or personnel records, and does not replace decisions made by responsible department offices.