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DignityMA Comments on Real Lives Bill

Self-Determination and Self-Directed Services

Download the letter on Self-Determination and Self-Directed Services (pdf)

Download the Facts Sheet from MA Alliance for 21st Century Disability Policy (MA21) on Self-Directed Services (pdf)

Letter to DDS

June 18, 2024
Department of Disability Services
Office of the General Counsel,
1000 Washington Street,
 Boston, MA 02118

SUBJECT: Self-Determination and Self-Directed Services

Dignity Alliance Massachusetts respectfully submits the following comments pertaining to proposed regulations at: 115 CMR 14.00: Self-Determination and Self-Directed Services.  115 CMR 14.00 implements G.L. c.19B, §19 – Self-determination option for individuals eligible for services (“Real Lives Bill,” Chapter 255 of the Acts of 2014).

For the record, Dignity Alliance Massachusetts is a statewide, all-volunteer, non-profit coalition advocating on behalf of older adults, people with disabilities, and their caregivers.

Dignity Alliance strongly supports the rights of all people, especially older adults and people with disabilities to independence, dignity, and self-determination.  We applaud the recommendations for improvements to the proposed regulations presented by the Massachusetts Alliance for 21st Century Disability Policy that are supportive of these essential goals. 

Essentially, Dignity Alliance supports improvements to the proposed regulations that:

  • Ensure a transparent assessment and budget allocation process. For those eligible but not priority 1, use the DDS “Community Based Day Supports” tool (CDAT) with an additional allowance for family support and transportation (use a median sum based on what persons receive in traditional services). For those eligible and priority 1 (includes residential), an additional allowance can be used based on the type of residential support needed (ALTR codes). 
  • Ensure broad budget authority consistent with the DDS individual support plan (ISP) and end the barriers on using organizations to provide support services of all kinds (in home, physical activity, musical/arts, other pursuits.  which are consistent with the individual supports plan (ISP).
  • Authorize and promote use of independent facilitators through policy.

Thank you for the opportunity to add our support for increasing self-determination and self-directed services for those in the disability community.


Paul J. Lanzikos
Coordinator, Dignity Alliance Massachusetts
35 High Street
Beverly, MA 01915

This testimony has been endorsed by twenty-two Dignity Alliance Massachusetts participants including the following:

  • Boston Center for Independent Living, Inc.
  • Center for Living and Work, Inc.
  • Lachlan Forrow, MD
  • Judi Fonsh, MSW
  • Wynn Gerhard
  • Arlene Germain, co-founder Dignity Alliance MA and MA Advocates for Nursing Home Reform
  • Margaret Morganroth Gullette, PhD
  • Chris Hoeh
  • Paul J. Lanzikos
  • James T. Lomastro, PhD
  • MetroWest Center for Independent Living
  • Former State Senator Richard T. Moore
  • Sue Rorke
  • SeniorCare Inc.
  • Dr. Patricia P. Shopland
  • Dorothy Weitzman, MA, MSW