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OK FUNDING FOR AT A Guide to Solving the Funding Puzzle and Receiving Assistive Technology in Oklahoma FOURTH EDITION, JANUARY 2005 Developed by OKLAHOMA ABLE TECH Oklahoma's Assistive Technology Program Oklahoma State University Seretean Wellness Center 2 Acknowledgments We are especially grateful to the staff members of all the Oklahoma and Federal public agencies along with private organizations listed within this document for their collaboration and cooperation in: • Sharing information about their programs and services; • Reviewing the information in this document for accuracy; • Disseminating information in this document for broader use. A special word of appreciation is extended to Joy Kniskern, a former staff member of the Georgia Assistive Technology Project, Tools for Life, whose funding guide provided the basis for much of the information contained in this guide. Thanks! Duplication: There are no copyrights on this document. Agencies, organizations, companies, individuals, and others are welcome to copy this document in whole or in part. Oklahoma ABLE Tech does ask that we are credited appropriately. “OK FUNDING for AT” is a publication of Oklahoma ABLE Tech. ABLE Tech is funded by U. S. Department of Education (USDOE). This publication does not necessarily reflect the position or policy of USDOE and no official endorsement of the material should be inferred. Information about the Oklahoma ABLE Tech program is available upon request as a public service. Oklahoma State University administers and conducts all program and activities in accordance with the U.S. Civil Rights Acts which provide that no person shall, on grounds of race, color, national origin, sex or disability be excluded benefits or be subject to discrimination under any program or activity receiving federal financial assistance. 2 OK FUNDING for AT FOREWORD OK FUNDING for AT: A Guide to Solving the Funding Puzzle and Getting Assistive Technology in Oklahoma is a collection of process and program information for use by individuals with disabilities, their families, advocates and service providers. We hope this “funding guide” will assist you in your search for funding, make the process easier and aid you in getting the assistive technology you need. This guide is dedicated to those individuals who work tirelessly to ensure that Oklahomans with disabilities have access to devices and technology that will enhance their independence, productivity, inclusion and quality of life. In addition, we also want to recognize ALL Oklahomans with disabilities, their families and advocates whose hard work and persistence continue to help us in the process of systems change. Agencies and service providers are currently gaining awareness of assistive technology. Eligibility guidelines, service provision policies and coverage issues are undergoing scrutiny and evaluation. In this era of change and growth, Oklahoma ABLE Tech will closely follow and continue to be actively involved in these changes. The information contained in this guide is the most current information available through September 2004. However, it is subject to change at any time. Thus, new information will be contained in future editions of OK FUNDING for AT. This guide describes possible public and private sources of funding and strategies to obtain funding for assistive technology from these sources. It is well organized and designed to be simple to use. It is our hope that OK FUNDING for AT will be used to help individuals understand public programs and to assist in identifying potential funding sources. Please share your experiences with us and with others. We have verified all the sources contained in this guide. However, if you know of other funding sources that are not included in the guide, contact us so we can include this information in our updates. If you have questions during the process of obtaining funding, or know of any information in this guide that needs to be changed or added, call us at the number(s) listed below. Please share your successes and experiences with us and submit copies of your requests for funding so that we can assist others in acquiring assistive technology. Contact Oklahoma ABLE Tech at: Oklahoma State University Seretean Wellness Center 1514 West Hall of Fame Stillwater, OK 74078-2026 In Stillwater (405) 744-9748 or Outside Stillwater, Toll Free (800) 257-1705 ABLE Tech INFO-line, Toll Free (888) 885-5588 Web site: http://okabletech.okstate.edu/ The Oklahoma ABLE Tech program is designed to make assistive technology devices and services more available and accessible to ALL Oklahomans with disabilities. OK FUNDING for AT was produced as part of this effort. Dr. Mac McCory Program Director Linda Jaco Program Manager Milissa Gofourth Policy/Funding Specialist Sherril York, PhD Outreach/Training Specialist Brenda Dawes Marketing Specialist Diana Sargent Staff Assistant Carla Wilhite, OTR/L AgrAbility Specialist 3 4 SECTIONS Section I: Introduction to Assistive Technology and Oklahoma ABLE Tech Section II: Developing a Funding Strategy Section III: Charts of Funding Sources Section IV: Public Sources of Funding Section V: Private Sources of Funding and Other Possibilities Section VI: Appendices Appendix A: Laws that Impact AT Appendix B: Public Agencies – Local Contacts Appendix C: Private Agencies – Local Contacts Appendix D: Additional Information Resources 5 Table of Contents Section I: Introduction Introduction......................................... 9 What is Assistive Technology?..................... 10 What is Oklahoma ABLE Tech?.................... 11 Section II: Funding Strategy Developing a Funding Strategy.................... Steps and Strategies to Acquire Funding........ Appeals and Advocacy.............................. Potential Funding Sources at a Glance.......... Glossary of Assistive Technology Terms......... Reference............................................ Section III: 14 14 19 21 22 24 Possible Funding Sources Possible Funding Sources.......................... 25 Public Sources........................... 26 Private Sources.......................... 29 Section IV: Public Funding Sources Aging Services....................................... American Indian Vocational Rehabilitation..... Family Support Assitance Program............... Head Start........................................... Home Improvement and Repair Loan & Grants Indian Health Service.............................. J.D. McCarty Center for Children with Disabilities.................. Medicaid - ADvantage Waiver Program.......... Medicaid - Early & Periodic Screening, Diagnosis, and Treatment.................. Medicaid - Fee for Service........................ Medicaid - Home and Community Based Waiver Program............................. Medicaid - In-Home Support Waiver Services.. Medicaid - SoonerCare Choice.................... Medicare............................................. Oklahoma ABLE Tech............................... Oklahoma AgrAbility Project...................... Oklahoma Department of Career Technology Education...................... Oklahoma Equipment Connection............... Oklahoma Library for the Blind and Physically Handicapped............... Oklahoma Telecommunications Program....... Senior Citizens Hearing Aid Project............. Social Security Disability Insurance............. Social Security Work Incentives Blind Work Expenses........................ Social Security Work Incentives Impairment-Related Work Expenses..... Social Security Work Incentives.................. SoonerStart - Early Intervention Program...... Special Education Programs...................... 6 36 37 39 40 41 42 43 44 46 48 50 52 54 56 59 60 61 63 64 65 67 68 Supplemental Security Income................... Supplemental Security Income Disabled Children's Program............... Supported Employment Program................. TRICARE.............................................. Veterans Benefits................................... Vocational Rehabilitation Program............... Vocational Rehabilitation Program............... Section V: 82 84 85 87 89 91 94 Private Sources of Funding Statewide Sources American Cancer Society Heartland Division......................... Angel Flight, Inc.................................... Arthritis Foundation Eastern & Oklahoma Chapters........... BancFirst Assistive Technology Lending Program............ BancFirst Access Telework Fund (ATF).......... Centers for Independent Living.................. Central Oklahoma Association for the Deaf and Hearing Impaired..... Dog Ears.............................................. Donna Nigh Foundation............................ Easter Seals of Oklahoma......................... Limbs for Life Foundation......................... Muscular Dystrophy Association Eastern and Western Oklahoma......... National Federation of the Blind of Oklahoma.................... National Multiple Sclerosis Society Oklahoma Chapter......................... P.A.L.S. - Practical Assisted Living Systems..... SHHH-Self Help for Hard of Hearing People, Inc....................... Sooner AMBUCS Share4Life Komputer (ASK)............................ Tulsa Cerebral Palsy Association.................. United Cerebral Palsy of Oklahoma, Inc. ....... 98 99 100 101 103 105 106 107 108 109 110 111 112 113 114 115 116 117 118 National Sources Disabled Children's Relief Fund................... Habitat for Humanity International.............. Multiple Sclerosis Association of America....... Pearle Vision Foundation.......................... Push America........................................ Recordings for the Blind & Dyslexic............. 70 National Rebates 72 74 76 78 DaimlerChrysler Corporation..................... Ford Motor Company............................... General Motors..................................... 119 120 121 122 123 124 125 126 127 Appendix A: AT Legislation Strategies Assistive Technology Act............................ Individuals with Disabilities Education Act (IDEA)....................... Americans with Disabilities Act (ADA)............ Section 504 of the Rehabilitation Act............ Section 508 of the Rehabilitation Act............ Private Health Insurance........................... Workers' Compensation............................. The Ticket to Work and Work Incentives Improvement Act (TWWIIA)............... 130 131 134 138 140 141 142 143 Appendix B: Public Agencies - Local Contacts Aging Services........................................ American Indian Vocational Rehabilitation Section 121 Project Contacts............. Certified Oklahoma Alternative Dispute System Programs........................... Head Start and Early Head Start Programs...... Indian Health Services Oklahoma City Area Service Unit Directory............... Oklahoma County Health Departments.......... Oklahoma Department of Career and Technology Education................ Oklahoma Department of Human Services County Offices.................... Oklahoma Department of Rehabilitation Services Division of Visual Rehab........ Oklahoma Department of Rehabilitation Services Division of Vocational Rehab... Oklahoma Rural Development Local Offices.... SoonerStart - Early Intervention Coordinators................................ 146 147 148 149 152 154 158 161 166 167 169 170 Appendix C: Private Agencies - Local Contacts BancFirst.............................................. Centers for Independent Living (CILs)............ Habitat For Humanity International – Oklahoma Affiliates........................ Legal Services of Oklahoma....................... Rehabilitation Hospitals and Clinics.............. 174 176 177 178 180 Appendix D: Additional Information Resources Frequently Used Oklahoma Resources........... 182 National Toll-Free Phone Numbers and Hotlines..................... 185 Directory of National Resources.................. 188 7 8 SECTION I Introduction to Assistive Technology and Oklahoma ABLE Tech 9 What Is Assistive Technology? Assistive technology is devices and equipment designed to make your life easier, or to help you perform specific tasks. If you are one of the 680,000 Oklahomans with disabilities, assistive technology devices becomes the door to opportunity and can assist you in realizing your potential. Technology can be a great enabler and an equalizer of opportunity. Assistive technology includes any mechanical, electronic or computer-based equipment, non-mechanical or nonelectric aid, or specialized instructional materials that people with disabilities can use to assist them in learning, making their home and/or work environment more accessible, competing in the work force, enhancing their independence or improving their quality of life and full inclusion at home, school, work and in the community. Assistive technology can help people with disabilities function more independently and includes computers, wheelchairs, listening devices, communication devices, environmental controls, ramps and many other devices and modifications. Assistive technology in the classroom brings children with and without disabilities together to share social and educational experiences. In the office or work setting, assistive technology enables people with disabilities to utilize knowledge and skills to be productive. At home, assistive technology makes life easier and more enjoyable. From simple to complex, assistive devices provide more opportunities and greater personal independence for people with disabilities. TYPES OF ASSISTIVE TECHNOLOGY (AT) For the purposes of this guide, the types of AT devices are divided into the following categories. Picture icons have been developed and included to represent each category of AT devices. These categories and icons have been used in this guide to quickly identify what types of AT devices are provided or covered by each funding source for eligible applicants. You may want to refer to this list when using the information on funding sources included in this guide. Adapted Toys & Games - adapted toys and games for young children such as battery operated toys for use with a single switch, adapted non-mechanical toys, and play boards. 10 Aids for Daily Living - devices for use in activities of daily living such as eating, bathing, dressing, toileting, grooming, cooking, cleaning, and home maintenance. Aids for Hearing Impaired - devices for persons who are deaf or hard of hearing such as hearing aids, TDDs, and visual alerting systems. Aids for Vision Impaired - devices for persons who are blind or visually impaired such as magnifiers, braille, speech output devices,and large print computer screens. Augmentative Communication- devices that provide a means for expressive and receptive communication for persons with limited speech such as electronic devices with speech output and nonelectronic devices (i.e., communication boards). Computer Applications - devices that enable persons with disabilities to use a computer such as special input devices (i.e., modified or alternate keyboards, switches), alternative access aids (i.e., mouthsticks, light pointers), special output devices (voice, braille), and special software. Educational Devices & Adaptations devices and adaptations that enable persons with disabilities of all ages to learn and benefit from educational programs such as computers, page turners and book holders, software, adapted instructional materials, and other modifications of the learning environment. Environmental Controls - primarily electronic systems that enable someone with limited mobility to control various devices such as appliances, electronic aids, and security systems in his or her home, school, worksite, or other setting. Home Modifications - structural adaptations and fabrications in the home that remove or reduce physical barriers for an individual with a disability (i.e., ramps, wider doorways, bathroom changes). Hospital Beds - special beds that allow for adjustments in positioning for persons with physical disabilities. Medical Devices & Supplies - devices and supplies that are needed for persons with health related conditions such as electronic glucose monitors, respirators, suctioning machines, and many other types of devices and related disposable supplies. Prosthetics & Orthotics - devices that a) replace or substitute for a missing body part such as artificial limbs (prosthetic device) or b) support or enhance the function of a malfunctioning body part such as splints and braces (orthotic device). Recreation & Leisure Devices - devices and modifications that enable persons with disabilities to participate in a) recreational activities such as adapted equipment for water skiing, wheelchair basketball, etc., or b) leisure activities using devices such as braille or large print playing cards or board games, adapted tools for gardening, books on tape, etc. Seating & Positioning Equipment - individualized modifications to a wheelchair or other seating system to improve body stability and sitting posture, provide trunk and/or head support, and reduce pressure on the skin surface (i.e., cushions, contour seats, lumbar and head supports). Vehicle Modifications - adapted driving aids such as hand controls, lifts, and modified vans or other motor vehicles used for personal transportation. Wheelchairs & Mobility Aids - devices to improve personal mobility for persons with physical disabilities such as manual and electric wheelchairs, walkers, crutches, motorized scooters, and other utility vehicles. Worksite & Office Modifications - structural adaptations and fabrications in the worksite that remove or reduce physical barriers for an individual with a disability (i.e., ramps, wider doorways, bathroom changes). What is Oklahoma ABLE Tech? Oklahoma ABLE Tech is a service of the Oklahoma State University Seretean Wellness Center, which is the lead agency for the “Tech Act” grant as designated by Governor Frank Keating. The mission of Oklahoma ABLE Tech is: “To facilitate systems change to enhance the provision of, access to, and funding for assistive technology so that individuals with disabilities can achieve their greatest potential. Through its task forces, committees, councils, and staff, ABLE Tech will help make changes to reduce or eliminate barriers that currently hinder technology-related assistance to individuals with disabilities." Oklahoma ABLE Tech is a valuable resource for persons with disablities, their families, advocates, and service providers. Although Oklahoma ABLE Tech does not purchase or sell AT devices they do provide the following services: • Free information and referral services on technology through the Oklahoma ABLE Tech INFO-line. This service is available to people of all ages with disabilities, their family members, service providers, and others who work in fields related to disabilties or to assistive technology. INFO-line's resources include a statewide computer database, national resources, a collection of AT catalogs, product literature, and a limited amount of vendor and evaluation information. • An AT recycle and resale program through the Oklahoma Equipment Connection (OEC). This is a free service to help Oklahomans with disabilities needing assistive technology to find affordable, used adaptive equipment to meet their needs. To buy, donate, or sell used AT call the Oklahoma ABLE Tech INFO-line or check our Web site. oec.okstate.edu • Educational and training workshops on assistive technology to consumers, parents, and professionals that serve individuals with disabilities. Training initiatives are directed toward: device utilization, agency staff development, programs, and services, technical assistance, public/private funding sources, and information technology. • A low interest bank loan through a partnership with BancFirst and the Oklahoma Assistive Technology Foundation also offers an Alternative Financing Program (AFP). The AFP provides Oklahomans with disabilities or those that have a dependent with a disability the opportunity to borrow money for the purchase of needed AT. • A low interest bank loan through a partnership with BancFirst and the Oklahoma Assistive Technology Foundation also offers an Access to Telework Fund (ATF) bank loan program. The purpose of the ATF is to provide an opportunity for Oklahomans with disabilities that want to telework to borrow money to purchase computers and other equipment. 11 • Assistance to farmers and ranchers through Oklahoma AgrAbility program. An AgrAbility specialist provides on-site assessments, information, and referral to Oklahoma farmers and ranchers with disablities to assist them in maintaining their agricultural lifestyle. • Technical assistance and training on accessible electronic and information technology to state agencies and other public and private entities. • A Listserv for individuals and organizations to communicate electronically. The Listserv is a public forum for conversation among parents, consumers, and people who work in the disability-related field. • A directory of programs that provide a short term loan or donation of assistive technology devices. 12 SECTION II Funding Strategy 13 Developing a Funding Strategy The first thing to remember when seeking funding for assistive technology (AT) is that funding is usually available. Though the journey may take a while and may try your patience. Do not give up! Persistence is the key, coupled with information. Step 3: Determine if an alternative device will meet the need. Answer: Is there an alternative device or equipment that will function equally as well? Is there a way to borrow, make, or fabricate this device or equipment? Step 4: Determining age, disability and other basic eligibility criteria will shorten the process and allow you to move through the subsequent funding steps. Knowing what device or equipment is needed and for what purpose(s) is an important factor, because ALL funding sources have a particular focus or purpose, such as vocational/ employment, education, medical, etc. Thus, knowing the purpose(s) or use of the assistive technology can assist you to narrow down your list of possible funding sources. Determine potential funding sources. Answer: What potential resources are available? Ask questions: seek out information, suggestions and guidance from your peers, services providers and professionals in the field of assistive technology. Learn ALL that you can! Gathering the right information and documenting your need(s) is fundamental in your approach to obtain funding and will become a core part of your request to the funding source(s). Submit appropriate applications and authorizations for approval. Answer: Did I provide the correct information? Steps and Strategies to Acquire Funding for Assistive Technology In developing a funding strategy, it is important to follow some basic steps to increase your chances of success. The development and use of funding worksheets can be beneficial and help you work with accuracy and efficiency. We also recommend that you keep a diary of names, phone numbers, and notes. The following steps and strategies are based on those presented previously in the Kentucky (Matheis, 1992) and North Carolina (Bell, 1993) funding guides developed by their state’s assistive technology project. We hope that these will be helpful to you in understanding the process of obtaining funding and in actually getting funding assistance. There are seven steps to acquire funding for assistive technology: Step 1: Define and document the need. Answer: Why is assistive technology needed? How do I document the need? Step 2: Identify the equipment and/or services needed. Answer: What assistive device, equipment, or service is needed? 14 Step 5: Gather all essential information to be submitted including necessary prescriptions and other justification. Answer: What information is necessary for each funding source to which I will apply? Step 6: Step 7: Seek appeals as appropriate. Answer: Why was my application denied? How do I file an appeal? The next few pages will include strategies, guidelines and suggestions that address each of these steps to help you as you move through the process. Step 1: Define and document the need. Why is Assistive Technology Needed? This involves identifying the areas in your life that you feel AT could assist you. You may already have some idea about how AT could provide you with fuller access, inclusion in society and improve your quality of life. However, you must clearly describe your need and exactly how AT could assist you at home, school, work and/or in your daily life in your community. To be successful in obtaining funding for AT devices and services, it is necessary to justify and document the need(s). At this point, it is wise to involve a professional and/or an advocate to assist you in documenting these need(s). This person should have a great deal of experience or information that will help you thoroughly and precisely document those needs. Describe the specific benefits of the AT and what the device will enable you to accomplish at home, school, work and/or in your daily life in the community. If seeking funding from health insurance providers, Medicaid, etc., determine the health-related and preventative benefits of the AT device (i.e., prevention of accidents/falls, further injury; prevention of physical or health deterioration; additional loss of function; employment; etc). Can the need for the AT device be described in terms of a “prosthetic” device (wording used in many private insurance policies)? HOW DO I DOCUMENT THE NEED? Proper documentation of need is critical throughout the process of obtaining funding for AT. First, you must document the need for AT. It is one thing to know that you need assistive technology. However, it is another thing to prove that need to someone else, which is exactly what you will have to do in documenting your need. If you have not obtained the assistance of a professional, you should do so at this point in the process. This professional might be a teacher or early interventionist, a speech therapist, a physical therapist, an occupational therapist, a vocational counselor, an independent living coordinator, an assistive technology technician, or a rehabilitation engineer. The necessary documentation may include input from a combination of these professionals, depending on your specific need(s). Involve one or more of these professionals throughout your request, but begin with the documentation of need. This is also the time to involve your advocate and other support persons that you may have. Detailed guidelines on documentation of the need are included in the next section. Step 2: Identify the equipment and/or services needed. What Assistive Device, Equipment, or Service Is needed? Once the need has been defined and documented, the AT devices and services required to fill this need must be identified and described. THIS IS THE CRITICAL STEP IN THE FUNDING PROCESS AND MUST BE DONE IN DETAIL. This includes a specific written justification from the appropriate professionals. This justification can take several forms: a) an evaluation or assessment report, b) a medical prescription, or c) other written justification you may need including letters of support. This information is used to develop a written “documentation of need” or justification and must be written in such a way that it convinces or proves to the funding source that you need the AT for specified purposes or outcomes. The extent, detail and scope of this written justification will also depend on which funding sources you decide to pursue. Later in the process you may find that you will have to come back to this step in the process for further documentation and/or clarification. No matter which funding sources are being approached for obtaining AT, it is vital that you demonstrate and document the need. The following is a list of supportive materials that are often essential in documenting these needs: • Physician’s prescription for the AT devices and/or services, and often a letter of medical necessity. For Medicare, Medicaid and other medical/healthrelated sources, there must be a determination of “medical necessity” to receive authorization for assistive technology. It is strongly recommended, and usually required, that the physician also write a letter substantiating this medical necessity. • Letters of medical necessity from the other licensed health care professionals involved in the case (physical therapist, occupational therapist, speech therapist, etc). • General discussion by the involved professionals of medical diagnosis that may further provide specific medical information and needs. • Detailed explanation of the individual’s functional skills and capabilities without the AT device or equipment and how these will be improved with the requested AT device or equipment. • Photograph or video of the individual, if it helps to demonstrate the need. • Literature concerning the specific AT device with specifications as they pertain to this individual. • Specifications of the AT device or equipment including cost, features and a catalog picture or photograph. At this point in the funding process, obtain prices for the AT devices and/or equipment identifying vendors or where it can be purchased. This can be very important because the funding source will always be concerned with the cost of the device or equipment and because the identified dealer of the equipment may be able to help you along in the process. Some funding sources, such as Medicaid and Medicare, ONLY purchase equipment from designated Durable Medical Equipment (DME) dealers that have completed their approval process and appear on their “approved vendor” list. If you plan to approach Medicare or Medicaid, you will have to locate such a dealer. Step 3: Determine if an alternative device will meet the need. Is There an Alternative Device or Equipment That Will Function Equally as Well? Based on past funding approvals and denials for assistive technology, you may need to determine if there are alternative devices that would also meet your need(s). Investigate these alternatives BEFORE applying to any funding source. You want to be as prepared as possible in order to make the process easier. 15 When reviewing your request, all funding sources will determine if the charge for the AT devices and/or services is reasonable and at a customary or typical rate. Also, the funding source may have to be convinced that the assistive technology is cost effective. To determine if a request is reasonable, consider the following questions: Is there a way to borrow, make or fabricate this device or equipment? • Can it be borrowed from an “equipment loan closet”? • Do the benefits of the device or equipment outweigh the expense? • Is there a less expensive device or service that meets your need(s) just as effectively? • Does the device or equipment serve the same purpose as the equipment that is already available to the individual? If there are no alternative devices that can be found that will meet your particular need, be sure that you have that fact well documented. Remember, do not let the cost of the assistive technology keep you from selecting the most appropriate AT device or adaptation for your need(s). This process of matching the technology to your needs is crucial to the successful use of AT once it is acquired. Guiding Questions • What AT device and/or service will achieve the targeted level of functioning? • What professionals are available who can help justify the medical necessity for the AT device (if pursuing medical/health related source)? • Is there a case manager or program coordinator assigned to the case? How can one be secured? • Where can the AT be obtained? • How much does it cost? Can it be rented? • Can the equipment manufacturer or local vendor provide any special assistance to you? • What additional services are needed, such as training, follow-up and maintenance of the device? Step 4: Determine potential funding sources. What Potential Funding Sources are Available? Now that you have determined what you need, you can begin the process of requesting funding assistance. You may choose to pay for it yourself, if that is possible, or you may be unable to contribute anything toward the 16 purchase of the AT device. There may be sources legally mandated or with the willingness to assist you. Before you approach any one source, it would be helpful to make a list of all possible sources and then prioritize them. This will give you ready options to go to if you have difficulty with your primary choice. The key, again, is to be well-prepared: with choices, with documentation, with determination. You may want to seek assistance in identifying and approaching funding sources. Possibilities would include the Durable Medical Equipment (DME) dealer, a case manager, a social worker, a case worker, a health care professional, or one of the professionals that helped you to identify the AT devices and/or services to meet your need(s). It is important to involve as many support people as possible. At this point in the process you should ask yourself the following questions: • Can you or your family pay for the device? • Do you have private health insurance? If so, does the policy cover the type of AT devices and/or services that are needed? • Are there public funding sources available and appropriate for the individual’s need and circumstances? • Are there limits to how much the programs pay? • Does your particular disability qualify and is there financial criteria that must be met? • Who will “own” the AT device or equipment, the individual or the public agency/program? • Are there private funding sources available? • What is the specific eligibility criteria for each one? • What is the application process? How long is the wait and are funds readily available? • Do you qualify for any low-interest loan program available through selected private sources? • Are there manufacturer or company rebates or discounts available for the specific AT device or equipment? • Does the equipment supplier or vendor have special approaches to financing? • Is a personal loan or home equity loan a possibility? A personal or home equity loan could be done as a last resort if you just do not wish to get involved with a lot of bureaucracy and red tape. Conventional bank loans, however, may be difficult to obtain for assistive technology. Also, Oklahoma ABLE Tech and BancFirst have developed the Alternative Financing, a customized lending program for financing assistive technology. When approaching funding sources, it is important to note that there is no one specific method to ensure funding. Traditional sources that have provided funding for assistive technology in the past are currently undergoing a period of adjustment. This is clearly a time when “precedence setting” may occur. A strategy that might be effective in another state may not be so effective in Oklahoma. If the assistive technology is a newly developed device, the funding source may take a conservative “hands-off” attitude. Knowing these things, it is important to plan your strategy and show patience and respect when dealing with prospective funding sources. Guiding Questions • What is the most likely source of funding? • Are there financial criteria? (Remember that this information will be verified by the agency. It is critical that all resources are reported.) • Have you dealt with this source before? Were you successful? What problems did you encounter? Who was the contact person? • Is there more than one potential source of funding available? • Is it possible for two different funding sources to coordinate payment that will equal or approach the total cost? • Are there individuals with disabilities who have been successful in receiving funding for the device you seek? • Will the device or service enable you to enter or continue employment, live more independently, enter or continue schooling or improve your overall health? Depending on the funding source, you may have to prove one or more of these benefits. How can the potential funding source be convinced of the benefits of the AT? • Are the written policy coverages of sources available? Review these for wording and specific jargon that will assist in writing the justification. • If you became disabled through a work-related accident, is the cost of the device or service the responsibility of worker’s compensation insurance? • Is there a local civic or charitable organization, foundation or association in your area that can help raise the necessary funds?Occurs Helpful Hints for Approaching Funding Sources • Be polite and pleasant, but always be businesslike. • Communicate in writing whenever possible and keep a copy for yourself. Encourage and develop a positive working relationship by directing letters or calls to the same person each time. • Maintain a routine connection with the funding source and DO NOT permit time gaps of three or more months between communication. • Maintain a record of ALL written and verbal communications. This is a time that you should NOT follow any “don’t call us, we’ll call you” practices. Remember, “the squeaky wheel gets the grease!” • Offer your cooperation and willingness to provide proof of medical necessity and to show how the technology will benefit the consumer and the funding source. • When questioned, try to educate and inform in an assertive, knowledgeable manner, emphasizing longterm monetary benefits to the funding source. • Remain patient and diplomatic while being persistent and assertive. • Never threaten the agency or company with legal action, unless you know that you are being discriminated against. This is an often-heard threat and will not intimidate any agency or insurance company. In fact, it often reduces your chances of getting what you want and/or delays the process significantly. • When someone (a case manager, therapist, durable medical equipment dealer, etc.) goes out of his or her way to help, express your sincere thanks and appreciation. • Document, document, document!!! Keep records of the names of people you spoke to, what was said, where you were referred to next. Step 5: Gather all essential information to be submitted including necessary prescriptions and other justifications. What Information is necessary for each funding source to which I will apply? Paperwork is an essential and necessary part of the funding process. Be prepared to provide extensive written support for your request. Ask specifically what information is required by the funding source. Understand exactly what is requested. If it is unclear or you are uncertain - ASK QUESTIONS and request clarification (written if necessary). The individual’s case manager, other service provider, DME dealer or advocate will typically assist you to gather and complete all the required paperwork. It is important to coordinate this activity with the funding source, and to remain closely involved. You will want to understand EXACTLY what is needed prior to submitting the request. Many funding sources may require you to resubmit the request with changes, particularly on expensive items. After the request for assistive technology has met all the necessary criteria and you have submitted all of the necessary paperwork, you will receive a decision of approval or denial from the funding source. 17 Step 6: Submit appropriate applications and authorizations. Did I provide the correct information? Each funding source requires specific information to be submitted. The required information will differ from one funding source to another. However, the following list contains information typically required by most funding sources: • Information about your age, disability/medical diagnosis, prognosis, evaluation reports, etc. • Information about your financial status including private insurance coverage, employment status, level and source of income, etc. (only needed when specific financial criteria are part of determining eligibility). Step 7: Seek appeals as appropriate. Why was my application denied? How do I file an appeal? If your request for funding is denied, you can appeal the decision. The appeals process is an opportunity for you, your family and/or the professionals working with you to approach the funding source and ask for a review of the initial decision. Often, the denial for funding for AT is due to a lack of understanding or knowledge of assistive devices by the eligibility determination specialist. ALL PUBLIC OR GOVERNMENTAL AGENCIES HAVE AN INTERNAL APPEALS PROCESS. YOU HAVE A RIGHT TO REQUEST AN APPEAL AND TO HAVE YOUR REQUEST OR CLAIM REVIEWED. The appeal can be strengthened by previously gathered evidence or documentation of how the device will help you medically/physically, vocationally, educationally and socially. Specifics on the appeals process for public agencies are included by agency in the fact sheets in Section IV: Public Sources of Funding. If possible, determine why your initial request was denied. Is further supporting information needed? Was there a lack of funds? Good rapport with the funding source personnel will prove helpful at this point. If you have dealt professionally and respectfully with agency personnel prior to this point, it is likely that these same professionals will be willing to discuss why the request was denied and will make suggestions to assist you in your appeal. Try to find evidence of whether the agency has previously funded such a device in the past. If so, a precedent has been set, and it will be more difficult for the agency to deny your appeal. 18 Assistive products and devices are becoming available at a much faster rate than are the funds to pay for them. Much of this new and innovative technology can be very expensive. The need for it will continue to be questioned by funding sources and denials will occur. You should be aware of the variety of assistive technology options which exist. • Information about public or governmental programs that you have previously used including Medicaid, Medicare, educational programs, social services, vocational rehabilitation, SSI and/or SSDI, traditional and nontraditional funding sources such as disability specific agencies (i.e., Easter Seals, MDA, UCP). • Recommendations for specific assistive devices including the name and manufacturer of the equipment, the cost, any amount that you or your family can contribute or information pertaining to financial assistance already guaranteed from another source, why the piece of equipment was selected and how the equipment will improve the functioning and/or health status of the individual. Again, make sure you know what specific information is required by the source. Always check your paperwork closely to be sure it is complete and correct. What Happens When Funding is Approved and Authorization Occurs? Written approval will be given for the amount of money that has been authorized toward the purchase of the specified assistive technology. If the approval is for the entire or full amount requested/needed, the AT supplier or vendor will process the order and deliver the equipment. If the approval is for less than the full amount, locate other options to fund the remaining amount. This is why it is important to determine ALL potential funding sources as soon as possible, so that you can expedite the process. Final Suggestion... Never give up when it comes to funding! Key components in successfully obtaining funding are: • Perseverance and determination. • Exercising self-advocacy. • Educating funding source personnel by demonstrating the benefits of the AT device. • Investigating and actively seeking alternate funding sources if necessary. Appeals and Advocacy In Oklahoma, there are several resources to assist you with the appeals process and/or to pursue other routes, such as legal action. These include the Client Assistance Program (CAP), Office of Handicapped Concerns, Office of Client Advocacy, Early Settlement Dispute Mediation Program, Oklahoma Disability Law Center and Oklahoma Parents Center. Office of Handicapped Concerns Steve Stokes, Director 2401 NW 23rd Ste 90 Oklahoma City, OK 73107-2423 (405) 521-3756 (Oklahoma City, voice) (405) 522-6706 (TDD) (800) 522-8224 (statewide, voice/TDD) FAX: (405) 522-6695 www.ohc.state.ok.us Office of Client Advocacy Client Assistance Program (CAP) The Client Assistance Program (CAP), a program within the Office of Handicapped Concerns, is the advocacy unit that assists eligible persons with complaints, appeals and understanding the 1998 Rehabilitation Act Amendments and Title I of the Americans with Disabilities Act (ADA). The CAP assists by: • • • • • • Investigating complaints Mediating conflicts Representing complainants in the appeals process Providing CAP legal services (if warranted) Advocating for due process Identifying and recommending solutions to system problems • Advising individuals of the benefits available under the 1998 Rehabilitation Act Amendments and ADA • Referring individuals to other agencies (when needed) Client Assistance Program (CAP) James Sirmans, Director Office of Handicapped Concerns 2401 NW 23rd Ste 90 Oklahoma City, OK 73107-2423 (405) 521-3756 (Oklahoma City, voice) (405) 522-6706 (TDD) (800) 522-8224 (statewide, voice/TDD) FAX: (405) 522-6695 www.ohc.state.ok.us/cap.htm Office of Handicapped Concerns The purpose of the agency is to provide information referral and technical assistance on issues effecting individuals with disabilities, develop and disseminate informational materials, and provide awareness and advocacy activities on a continuous basis. This State Agency has three statewide programs that provide information, referral, technical assistance, and employment development to individuals with disabilities and businesses and governmental entities on various topics concerning the disabled. The Office of Handicapped Concerns helps businesses and other agencies meet the accessibility requirements of individuals with disabilities. The Office of Client Advocacy, Oklahoma Department of Human Services (DHS) is the DHS advocacy unit that assists eligible persons with complaints and appeals regarding DHS services. The Office of Client Advocacy assists by: • • • • • Investigating complaints Mediating conflicts Representing complainants in the appeals process Advocating for due process Identifying and recommending solutions to system problems • Referring individuals to other agencies (when needed) Office of Client Advocacy Oklahoma Department of Human Services PO Box 25352 Oklahoma City, OK 73125 (405) 525-4850 (800) 522-8014 (statewide) FAX: (405) 525-4855 www.okdhs.org/clientadvocacy/ Early Settlement Dispute Mediation Program In 1986 the Supreme Court of Oklahoma adopted Rules and Procedures for the Dispute Resolution Act, O.S. 12§ 1801 et seq., providing guidelines for the establishment of dispute resolution centers. The purpose of the Dispute Resolution Act is to provide all citizens of this state convenient access to dispute resolution proceedings which are fair, effective, inexpensive, and expeditious. Early Settlement Centers operate under the authority of the Oklahoma Dispute Resolution Act. The Centers provide low-cost mediation services to all who wish to negotiate interpersonal matters. To initiate mediation, each party must pay a $5 processing charge as required by Oklahoma Statute, except in cases ordered through the court. Almost any issue can benefit from the Early Settlement program and it's services. Cases resolved by mediation may involve services to individuals with disabilities (including school services to children with disabilities under IDEA), money, property and business transactions. Mediation is not a substitute 19 See Appendix B for a list of the Early Settlement Regional Offices. Oklahoma Parents Center 4600 S.E. 29th, Suite 115 Del City, OK 73115-4224 E-mail: okparentctr@aol.com (405) 619-0500 (877) 553-4332 (Voice/TDD) FAX: (405) 670-0776 (Toll Free for Parents Only, Please) www.okparents.org Oklahoma Disability Law Center (ODLC) Legal Aid Services of Oklahoma, Inc. The Oklahoma Disability Law Center is a non-profit corporation providing free legal services throughout the state to persons with disabilities. They help individuals achieve equality and inclusion in society without regard to disabling conditions. Their mission is to protect, promote, and expand the rights of people with disabilities. Their professional staff will determine whether or not they can help with legal services. Because of their very limited resources, they may be unable to help all eligible persons. ODLC has offices in Tulsa and Oklahoma City. Legal Aid Services of Oklahoma, Inc. is a nonprofit Oklahoma corporations providing free legal services to Oklahoma's poor as well as its senior citizens. Legal Aid maintains high standards of quality in providing effective and efficient legal services to its client community through a professional staff of attorneys, paralegals and support staff. These services are supplemented by volunteer attorneys. Legal Aid may handle the following problems: for legal help and no legal advice will be given by the mediator. Participants retain their rights to due process hearings, court action or filing complaints with appropriate agencies. Early Settlement Hotline (405) 521-6677 Oklahoma Disability Law Center, Inc. 2828 E. 51st Street, Suite 302 Tulsa, OK 74105 (918) 743-6220 (V/TDD) (800) 266-5883 (V/TDD) http://home.flash.net/~odlcokc/ Oklahoma Disability Law Center, Inc. 2915 Classen Blvd. 300 Cameron Bldg. Oklahoma City, OK 73106 (405) 525-7555 (V/TDD) (800) 880-7755 (V/TDD) Oklahoma Parents Center, Inc. Oklahoma Parents Center (OPC) is a statewide parent training and information project. It is a parent directed center providing services statewide to parents and professionals enabling them to work together to provide an appropriate educational program for the disabled child. Oklahoma Parents Center can help parents of children with disabilities meet their needs for specialized information, skills and training. Oklahoma Parents Center provides the following free services statewide: Workshops: • Basic Rights/Related laws; • IEP (Individualized Educational Program); • Communication Skills; • Early childhood 0-5 transition (School to Work/ Home to Community) • Parent Volunteer Advocates • Specialized Workshops/Presentation • Individual Assistance and Information • Newsletter 20 • Public Assistance: TANF, Food Stamps, SSDI, SSI • Health Care: Medicaid/Medicare, Nursing Home Problems • Housing: Public Housing/Section 8 Housing, Foreclosures, Evictions • Education: IDEA, Vocational Education, School Expulsion and Suspension • Special Legal Problems: Rights of the Mentally or Physically Disabled There may be other types of cases that can be handled. Please ask. Unfortunately, because of limited resources, they are unable to assist many individuals. For assistance, call for an appointment. See Appendix C for a list of the regional Law Centers. Legal Aid Services of Oklahoma, Inc. Headquarters and Administration 2915 Classen Blvd #10 Oklahoma City, OK 73106 (405) 557-0020 (V/TDD) (800) 421-1641 (V/TDD) FAX: (405) 524-1257 www.legalaidok.org Legal Aid Services of Oklahoma, Inc. Tulsa Law Center and Administration Services Gary Dart, Director of Litigation 423 S.Boulder, 2nd Floor Tulsa, OK 74103 (918) 584-3338 or (918) 584-3211 (800) 299-3338 Hotline: (888) 534-5243 FAX: (918) 584-3060 or (918) 584-1866 www.legalaidok.org AIDS Legal Resource Project: (866) 817-8151 Homeless Legal Assistance Program: (800) 299-3338 Tulsa area only: (918) 584-3338 POTENTIAL FUNDING SOURCES AT A GLANCE FOR PEOPLE WITH DISABILITIES IN OKLAHOMA Additional Sources Across Age Groups include Private Sources, Service Clubs, Fraternal Organizations, Low Interest Loan Programs, Charitable Organizations, Grants, and Foundations PRE-SCHOOL AGE SoonerStart Head Start Special Education Private Insurance Medicaid Medicaid - Home & Community Based Waiver Social Security Income (SSI) SSI - Disabled Children's Program Family Support Assistance JD McCarty Ctr for Children with Dev Disabilities Oklahoma Telecommunications Program Easter Seals of Oklahoma Muscular Dystrophy Association WORKING AGE Medicare Private Insurance Medicaid Medicaid - ADvantage Waiver Medicaid - Home & Community Based Waiver Social Security Disability Insurance (SSDI) Social Security Income (SSI) Vocational Rehabilitation Supported Employment Veterans Benefits Oklahoma Telecommunications Program Independent Living Services US Dept of Housing and Urban Development Muscular Dystrophy Association Corporate Discounts and Rebates SCHOOL AGE SENIORS Special Education Head Start Private Insurance Medicaid Social Security Income (SSI) SSI - Disabled Children's Program Medicaid - Home & Community Based Waiver JD McCarty Ctr for Children with Dev Disabilities Family Support Assistance Vocational Rehabilitation Supported Employment Oklahoma Telecommunications Program Easter Seals of Oklahoma Muscular Dystrophy Association Corporate Discounts and Rebates Medicare Private Insurance Medicaid Medicaid - ADvantage Waiver Social Security Disability Insurance (SSDI) Social Security Income (SSI) Home Improvement and Repair Loan, USDA Veterans Benefits Oklahoma Dept. of Housing and Urban Development Oklahoma Telecommunications Program Private Funds Corporate Discounts and Rebates Senior Citzens Hearing Aid Project 21 GLOSSARY OF ASSISTIVE TECHNOLOGY TERMS Activities of Daily Living (ADL) - Activities that reflect a person's ability to perform tasks that are essential for selfcare, such as bathing, grooming, feeding oneself, dressing, toileting, and mobility including walking, transferring, or independently using a wheelchair to move from one place to another. advocacy - Speaking or acting on behalf of someone to protect his or her rights and needs. alternative and augmentative communication (AAC) Any system that aids individuals who are not independent verbal communicators. The system can include speech, gestures, sign language, symbols, synthesized speech, dedicated communication aids or microcomputers. Americans with Disabilities Act (ADA) - The Americans with Disabilities Act (ADA) of 1990 assures full civil rights of people with disabilities. Guarantees equal opportunity for individuals with disabilities in employment, public accommodations, transportation, state and local government services and telecommunications. encoding - A selection technique used to specify items from an individual’s vocabulary. For example, an individual may select DW on a communication device to say “I want a drink of water.” environmental adaptations - Modifications or changes made to an individual’s environment (e.g., home, work, school, community) to assist in living independently. These modifications include ramps, widening of doorways, modifying bathrooms, special furniture, other additions of equipment, etc. environmental control unit (ECU)- A system that enables individuals to control various devices in their environment with single or multiple switches. The control unit may be mounted on a wheelchair for ease of access. Devices that can be operated with ECUs include lights, door openers, televisions and telephones. equipment fabrication - The design and construction of a device or piece of equipment that improves an individual’s functioning level. appeal - A process which takes place after a request or application is denied. Additional information is supplied to the funding agency so they may reconsider the request. equipment fitting - The process of installing, adjusting, and testing an AT device, piece of equipment or other adaptation that will benefit an individual. assistive technology device - Any item, piece of equipment, or product system, whether acquired commercially off the shelf, modified, or customized, that is used to increase, maintain or improve functional capabilities of individuals with disabilities. equipment modification - Changing or altering of the design and construction of an existing device or piece of equipment. assistive technology (AT) - A generic term to describe any device that is mechanical or non-mechanical, electronic, non-electronic, computer-based or any specialized or adapted materials and/or strategies. assistive technology service(s) - Any service that directly assists an individual with a disability in the selection, acquisition, or use of an assistive technology device. These include evaluation and assessment, acquisition and/or purchase, coordination with existing services, training and technical assistance for an individual with a disability and/or the family, and training or technical assistance for service providers and employers who are substantially involved with the individual. direct selection - Activation of a letter, picture or other item by a single action. Pressing a key on a keyboard, eye gaze selection (eye pointing) or use of an optical headpointer are examples of direct selection. durable medical equipment (DME) - A piece of equipment that can withstand repeated use, is primarily and customarily used to service a medical or therapeutic purpose, is generally not useful to a person in the absence of illness or injury, and is appropriate for use in the home. 22 expanded keyboard - A keyboard which has keys and/ or spaces between the keys larger than the standard microcomputer keyboard so that persons with poor fine motor control (hand and finger use) can use the enlarged keys/keyboard. Free and Appropriate Public Education (FAPE) - IDEA requires state and local education agencies that accept Federal funds to provide a FAPE, in the least restrictive environment, for ALL children with disabilities who are ages 3-21. headstick or mouth stick - A pointer or extension device that is mounted to a headpiece and extends downward or is held in the mouth between the teeth. It is used in direct selection of keys on a keyboard or a picture symbol or word on a communication board. It is for use by persons with good head control who have very limited use of their upper body (arms and hands). icon - A graphic used to represent a concept or idea. Icons can appear on the computer screen or in print format. For example, icons have been used in this guide to represent each category of AT devices (i.e., a van to represent vehicle modifications). inclusion and integration - Use of the same community resources available to others. Contact and interactions with citizens without disabilities including physically, socially, academically or vocationally and societally. independence - The extent a person with a disability can exert control and choice over his or her own life. Individual Education Plan (IEP) - A plan used to document appropriate and individualized education. The IEP puts in writing the child’s current level of functioning, annual goals, short-term objectives and support and/or related services needed to achieve these goals and objectives (including the need for AT devices and services). Individualized Plan for Employment (IPE) - A written plan developed by a consumer and a vocational rehabilitation counselor to outline all the services needed to find employment and an appropriate career of the consumer's choice. input device - A method of activating or sending information to a computer or other electronic device. Keyboards, mice and trackballs are common computer input devices. interdisciplinary team - Individuals involved in assessment and recommendations for persons with disabilities. The team consists of persons from a wide variety of disciplines including, but not limited to, medical experts, educators, speech language pathologists, occupational therapists, physical therapists, rehabilitation engineers, care providers, psychologists, rehabilitation counselors, and social workers. medically necessary - Items that are needed by the consumer for medical reasons. These items need to be ordered by a doctor or other appropriate medical professionals. Medical necessity is a judgement made by the individual doctor or medical professional. miniature keyboard - Although smaller than the standard keyboard, a miniature keyboard contains all of the keys and functions. It is useful to persons with limited range of motion and one-handed typists. occupational therapist - occupational therapists help persons with both physical and emotional problems. The term "occupation" used in the context of this profession refers to any activity with which persons occupy their time. Occupational therapists focus on helping people master the everyday activities of life and work. orthotics - The selection, fabrication and fitting of devices used to protect, support, or improve the function of parts of the body. Any device of this type is called an orthosis or an orthotic device (plural - orthoses). peripheral - Any number of devices connected to a computer to provide input, output, or other functions. Printers, modems, switches, voice synthesizers, and internal memory cards are considered peripherals. physical therapist - physical therapists are health care professionals who evaluate and treat people with health problems resulting from injury or disease. prior approval - An agreement in writing that ensures payment of a device. Eligibility for prior approval must be determined by the funding source (agency) BEFORE the purchase of the device. prosthetics - The selection, fabrication and fitting of devices (artificial limbs) used to replace the function of parts of the body that move (i.e., arms, hands, legs, feet). Any device of this type is called a prosthesis or a prosthetic device (plural - prostheses). scanning - A selection technique which presents groups of items to the user. The user then signals with a switch press, gesture or other means when the desired item is being indicated. The scanning may be performed automatically by an electronic system or manually by the communication partner. speech language pathologist (SLP) - professionals that provide treatment of speech defects and disorders, especially through use of exercises and audio-visual aids that develop new speech habits. speech synthesizer - An electronic device that converts text characters into artificial speech. The quality of speech ranges from close to lifelike to robotic sounding speech found in lower end speech synthesizers. Telecommunication Device for the Deaf (TDD) - A Telecommunication Device for the Deaf allows a person to transmit typed messages over the phone lines to another person with a TDD. Most TDDs include a keyboard for typing messages to send and a display and/or printer to receive messages. touch screen - An input device which allows access to a computer by directly touching the screen. voice recognition system - An access system designed to replace the standard keyboard as the method of input. The system is “trained” to recognize utterances that are spoken into a microphone. The utterances are translated into computer commands or sequences of alphanumeric characters and used to operate the computer and software. 23 References Bell, S. B. (1993). Guide to funding assistive technology. Raleigh, NC: North Carolina Assistive Technology Project, Division of Vocational Rehabilitation Services. Other Sources* Department of Veterans Administration. (1988). Federal benefits for veterans and dependents. Washington, DC: U.S. Government Printing Office. Golinker, L. (1991). The buck starts here . . . 1) Augmentative communication devices & services; 2) Computer & environmental control devices; and 3) Seating, positioning & mobility devices & services. Frankfort, KY: Kentucky Assistive Technology Service Network, Department for the Blind. Matheis, D. (1992). The buck starts here . . . A guide to assistive technology funding in Kentucky. Frankfort, KY: Kentucky Assistive Technology Service Network, Department for the Blind. Morris, M. W., & Golinker, L. (1991). Assistive technology: A funding workbook. Washington, DC: RESNA Press. Reeb, K. G. (1987). Private insurance reimbursement for rehabilitation equipment. Washington, DC: Electronics Industries Foundation. RESNA Technical Assistance Project. (1992). Assistive technology and the Individualized Education Program. Washington, DC: Author. Social Security Administration. (1988). A summary guide to social security and supplemental security income work incentives for the disabled and blind. Washington, DC: Author. Georgia Division of Rehabilitation Services. (1992). A guide to assistive technology services. Atlanta, GA: Author. Hofmann, A. C. (Ed.). (1987). The many faces of funding. Mill V
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