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Memory Care in New York

Nearly 20 million people live in the state of New York, and 17.5% of this population are seniors. Current projections predict that the senior population will rise, increasing the need for dementia care in New York. Alzheimer’s deaths in New York increased by 24.55% between 2016 and 2020, reflecting a nationwide ranking of Alzheimer’s as the 7th leading cause of death in the country.

Memory care communities are a form of dementia care that takes place in a residential setting. At a memory care community, seniors with Alzheimer’s or dementia receive around-the-clock care and supervision from trained caregivers. Families exploring memory care options in New York can use this guide to compare average costs, learn about services and find local resources for care planning.

The Cost of Memory Care in New York

When trying to decide how to pay for memory care, one of the first questions that comes up is "How much does it cost?" With the impact of inflation, it's more important than ever to have up-to-date information when making a financial plan for senior living. To help shed light on real senior living prices, Caring.com has compiled proprietary cost data from its network of over 75,000 senior living providers to offer insight into the average cost of memory care in New York and its 37 cities.

The Cost of Memory Care in New York's Top Cities

The cost of memory care can vary widely, even within the same state. Seniors in Buffalo pay an average of $4,832 per month, while in East Amherst, the price rises to $5,767. In the state’s largest city, New York, the average price is $6,295 and in Syracuse costs average $6,456. This shows that location is an important consideration when making memory care plans.

New York

$6,449

New York City

$6,295

Buffalo

$4,832

Syracuse

$6,456

East Amherst

$5,767

Inflation's Impact on the Cost of Memory Care in New York

Inflation is having an impact on memory care costs in New York. From 2022 to 2023, prices rose 23% from $5,244 to $6,449. The U.S. average had a more modest increase of 10% to $5,369. The picture in neighboring states is different. In Pennsylvania, costs rose by 12%, while in New Jersey they fell by 11%. Memory care prices in Connecticut and Massachusetts didn’t change much at all, with a decrease of 1% and increase of 2% respectively.

Location2022 Cost (Historical)2023 Cost (Current)2024 Cost (Estimated)
New York$5,244$6,449$6,416
U.S. Average$4,863$5,369$5,792
New Jersey$7,091$6,289$6,787
Connecticut$7,310$7,257$7,637
Pennsylvania$4,649$5,201$5,931
Massachusetts$7,570$7,706$7,782

The Costs of Other Types of Senior Living

Memory care is one of the more expensive senior living options in New York, with an average cost of $6,449. Assisted living prices average $4,699 and independent living is the most affordable choice at $3,372. Higher costs generally denote a larger range of services, such as personal care and specialized memory care services. 

Assisted Living

$4,699

Memory Care

$6,449

Independent Living

$3,372

Does Medicaid Cover Memory Care in New York?

Note: For the purposes of this guide, when we say “Memory Care” we are referring to memory care provided in a “social setting,” such as an Assisted Living Facility. This is the most common way to receive Memory Care and is the best fit for all but the frailest seniors. Sometimes the actual service of memory care can be provided in a Nursing Home (“medical setting”), so the financial assistance options will be very different. To learn more about the financial assistance options available for memory care provided in a nursing home, read our guide to Nursing Home Care in New York.

Seniors in New York who qualify for Medicaid may be able to get help paying for residential memory care services through two waiver programs. Both of these programs are designed to help people who require a nursing home level of care continue to live in the community. Both programs allow services to be provided in an assisted living environment.

What Memory Care Services Are Covered by Medicaid in New York?

The waiver programs in New York generally pay for the services provided in a residential care setting. This can include personal care services, such as assistance with activities of daily living, case management and adult day health care. Medical aid offered includes intermittent skilled nursing and occupational therapy. 

Memory Care Waiver Programs in New York

Managed Long Term Care Program Waiver

The MLTC program is intended to help people with chronic illnesses or disabilities, including memory loss, get the care they need without entering a nursing home. People in the program enroll in a managed care plan, which has a network of health care providers, and after enrolling, you must get services from your plan’s providers. 

There are three types of plans available for people in the program: MLTC Medicaid Program, Medicaid Advantage Plus (MAP) and Program for All-Inclusive Care for the Elderly (PACE). The MLTC Medicaid program keeps Medicaid and Medicare separate, while MAP and PACE combine Medicaid and Medicare services into one plan. 

Enrollment in the program is mandatory for anyone who is over 21, dual-eligible for both Medicaid and Medicare and in need of long-term care for at least four months. Enrollment is voluntary for adults who aren’t dual-eligible. In addition to these criteria, applicants must meet Medicaid’s income and asset limits and must require a nursing home level of care. Participants can’t be enrolled in MLTC and another waiver program, such as ALP, at the same time. 

The exact benefits differ slightly depending on the type of plan you choose, mainly because some plans combine Medicare and Medicaid services. All plans provide care management, home care and other community long-term care services. These can be provided in an assisted living setting. Other services include occupational therapy, vision and hearing aids and medical social services. 

Applications for the program are made through local Department of Social Services offices

Assisted Living Program

The Assisted Living Program uses a mix of Medicaid and non-Medicaid funding to pay for the cost of assisted living services in licensed assisted living residences. This hybrid funding model means it can pay for both care services and room and board for qualified participants. 

The program is available to both Medicaid recipients and private payers. Applicants must still meet the financial and residency criteria to be eligible for Medicaid and must require a nursing home level of care. The program isn’t available to people who are bedridden, need constant nursing care or who are impaired in a way that endangers other residents.

The ALP pays for the basic cost of assisted living. Services provided include case management, personal care, room and board, recreational activities and supervision. On the medical side, skilled nursing, some therapies and medical supplies and equipment can be included. It’s important to note that basic costs may not cover every service that’s offered in a facility. Some memory care services may be offered in addition to the basic services and would need to be paid for by other means. 

As of February 2022, the ALP is only funded for 4,200 participants and new applicants are put on a waiting list. If eligible for other programs, such as MLTC, you may still be able to get assistance paying for care in assisted living, although room and board costs won’t be covered. 

The Department of Health recommends that interested seniors contact participating assisted living providers in their area to see if there’s a position available. New York’s Adult Care Facility Directory does state whether the facility has beds in the ALP and is a good place to start if you’re looking for a facility. Local Department of Social Services offices can also offer assistance. 

How to Know if You’re Eligible for Medicaid in New York

Medicaid in New York can help low-income residents from all walks of life access health care. Eligibility is based on a number of criteria, including finances, residency and health status. The criteria can differ depending on your circumstances. 

To be eligible for the waiver programs included in this guide, you must:

  • Be a New York resident
  • Be a U.S. citizen, national, permanent resident or legal alien
  • Be aged 65 or older, be legally blind or have a qualifying disability
  • Have an income of less than $1,677 per month if single or $2,268 if applying as a married couple
  • Have assets of less than $30,182 if single or $40,821 if applying as a married couple

If only one spouse is applying, the single limits apply. However, the non-applicant spouse can have up to $148,620 of assets and is entitled to a Community Spouse Monthly Income Allowance (CSMIA). Not all assets are included when making Medicaid assessments. Exempted assets include your primary home along with personal belongings, household items and a vehicle.

2022 Medicaid Income Limits for Seniors in New York

Household SizeNumber of ApplicantsIncome Limits Per Year*Asset Limits: Applicant(s)Asset Limits: Non-Applicants
One Person1$20,124$30,182
Two Person1$20,124**$30,182$148,620
Two Person2$27,216$40,821

*Depending on the facility setting, a recipient may not be able to keep income up to this level.

**Income limit is for applicant only.

 

People who don’t meet the financial eligibility requirements may be able to access Medicaid through alternative pathways. These allow seniors to spend extra assets or income on approved expenses, such as medical needs, until they reach the financial limit. Once this limit is reached, the individual is considered Medicaid-eligible until the end of the period. 

How to Apply for Medicaid in New York

Medicaid applications can be made through a local Department of Social Services office or online at the NY State of Health website. The department recommends that people aged 65 and over apply with the Department of Social Services, unless they are the parent or caretaker relative of a minor family member.

Information You Will Need

When applying for Medicaid, people aged over 65 must provide proof of:

 

  • Identity and date of birth
  • U.S. citizenship or immigration status
  • Current address
  • Current income
  • Health insurance, such as current policy, termination letter or Medicare card
  • Medical bills for the last three months
  • Resources, including bank account statements, and stock and bond certificates

How to Get Help Applying for Medicaid

New York has a number of programs available to help seniors apply for Medicaid, including the statewide Navigator program and the Health Insurance Information, Counseling, and Assistance Program. Local Department of Social Services offices can also provide assistance. 

ProgramContactServices provided
NavigatorFind local numbers onlineNavigators offer in-person enrollment assistance to people applying for health insurance through the Marketplace. This includes some Medicaid applicants. Assistance is available in a number of languages.
Health Insurance Information, Counseling, and Assistance Program (HIICAP)1-800-701-0501HIICAP helps educate people about Medicare, Medicaid and other health insurance programs in the state. Counselors can help people determine their eligibility, resolve complaints and provide unbiased information.
Department of Social ServicesFind local numbers onlineLocal offices of the Department of Social Services take applications from Medicaid applicants and can also answer questions about eligibility, available benefits and more.

Does Medicare Cover Memory Care in New York?

The short answer is that no, Medicare does not cover the cost of memory care in New York. As was mentioned above, this doesn’t apply to Memory Care received in a Nursing Home. Since it is the most common to receive memory care in a “social setting” (such as an assisted living facility), Medicare won’t be a viable financial assistance option for most seniors who need Memory Care. However, Medicare will still cover things like approved medications, doctor visits, medical equipment, etc., just like it would if you lived at home.

For more information about when Medicare can be used to pay for Memory Care in a nursing home, and for Medicare-related resources, see our guide to Nursing Homes in New York.

Other Financial Assistance Options for Memory Care in New York

Seniors who are not eligible (due to location, financial situation, or other factors) for other types of financial assistance, do still have some options. See the table below for an overview of some of the most common ways to make Memory Care affordable.

NameHow To ApplyHow It Works
Aid and AttendanceLearn more and apply online at va.gov.Veterans who receive a VA pension may also be eligible for the Aid and Attendance benefit, a monthly cash allowance that veterans receive in addition to their standard pension amount. The benefit is intended for veterans in need of long-term care services and may be used toward paying for Memory Care.
Reverse MortgagesLearn more about your options and how to apply at ftc.govIf you own a home, you may be able to use a reverse mortgage to help pay for Memory Care. Reverse mortgages are loans that an individual can take out against the value of their home, essentially converting some of the home's equity into cash. These loans do need to be repaid with interest, typically within 12 months of receiving the loan.
Long-Term Care (LTC) InsuranceLearn more about Long-Term Care Insurance and how to apply for a policy at acl.gov.Seniors who already have long-term care insurance may be able to use it to pay for Memory Care. Most policies cover at least a portion of the cost, but it depends on the specific policy terms. Note that older adults who are already in need of Memory Care will not typically be eligible to sign up for LTC insurance.

Free and Low-Cost Resources for Seniors in New York

There are many resources in New York that assist seniors in their retirement. Caring.com has compiled information on local organizations, programs and agencies and categorized them into care types for easy reference.

 

ResourceContactService
Special Needs Assisted Living Residence Voucher ProgramContact via email ALTCteam@health.ny.govThe SNALR Voucher Program is a demonstration program that helps adults with Alzheimer’s disease or dementia pay for care in an assisted living setting. It’s designed to prevent enrollment in Medicaid and isn’t available to those who are Medicaid-eligible. The vouchers subsidize up to 75% of the average monthly cost for care in the region. Because it’s a demonstration program, there is a waitlist for new applicants.
NY Connects1-800-342-9871NY Connects provides information about resources and support available in the state. The free service is designed to connect older adults and people with disabilities with long-term services and support. It also coordinates with other agencies and helps people navigate eligibility, application and enrollment processes.
Elderly Pharmaceutical Insurance Coverage1-800-332-3742The Elderly Pharmaceutical Insurance Coverage (EPIC) program helps low-income seniors aged 65 and over supplement their Medicare Part D drug plan costs. There are different benefits depending upon income, including assistance to pay premiums and lowering deductibles.
New York Office for the AgingLocal numbers on websiteNew York’s Office for the Aging coordinates a wide range of programs designed to help older adults. Its local offices are the Area Agencies on Aging in the state, which can be found in every county. The department can assist with housing, meal programs, transportation and more. It also runs the Long Term Care Ombudsman Program in New York.
Centers of Excellence for Alzheimer’s DiseaseContact your local CEAD officeThe Centers of Excellence for Alzheimer’s Disease are 10 medical centers and teaching hospitals that specialize in the diagnosis and treatment of people living with Alzheimer’s disease or other forms of dementia. In addition, the centers provide support to caregivers, information and access to clinical trials and connect people with community-based resources.
Alzheimer’s Disease Community Assistance ProgramContact your local DCAP office or the helpline on (800) 272-3900This statewide program is run in conjunction with local Alzheimer’s Association chapters. Services are designed to postpone or prevent nursing home placements and include support groups, care consultations and training and education for both caregivers and those with Alzheimer’s disease or dementia. In addition, there’s a 24-hour helpline that can provide information and referrals to local resources.

Area Agency on Aging

Retirees can find support and advice on various senior-related issues from their local Area Agency on Aging. The agency provides advice on topics such as financial assistance programs, in-home care and long-term care planning. It also connects seniors and caregivers with community-based resources.

Program NamePhone NumberDescription
New York Area Agencies on AgingNew York State has 59 Area Agencies on Aging, and they offer services to seniors that include legal services, home-delivered meals, transportation, social adult day services and case management. Seniors can also learn more about volunteer opportunities, get help with their insurance and receive advice about proper nutrition. Support is available to caregivers who need guidance or information about resources.

Cash Assistance Programs

Cash assistance programs in New York provide financial support to help low-income retirees remain in their own homes for as long as possible. Seniors and caregivers can apply for tax rebates and reductions, discounts on vital services and help covering the cost of heating and cooling their home.

Program NamePhone NumberDescription
New York Department of Social ServicesNew York's Department of Social Services plays a significant role in providing financial assistance for senior care. Through various programs and initiatives, the office offers support for seniors who require long-term care services. The department administers benefits such as Medicaid and Supplemental Security Income (SSI), which can help cover care costs for assisted living and nursing homes. It also offers a Home Care Services program, which gives seniors a number of in-home options should they choose to age in place.
New York Lifeline Program800-234-9473The LifeLine Program offers a discount on landline or mobile telephone service, ensuring that participants can stay in contact with loved ones.

Financial Assistance for Senior Care and Senior Living

Whether living in their own home or in a senior living community, New York seniors can find financial assistance from numerous local resources. These organizations help residents cover some of the costs associated with in-home or long-term care and connect them with other helpful community-based resources.

Program NamePhone NumberDescription
New York BenefitsCheckUp800-794-6559Benefits Checkup is a nationwide service that helps seniors understand their eligibility for benefits such as financial assistance to pay for food, medicines, health care and utilities. The service can outline what benefits are available locally and assist seniors with the application process.
New York NY ConnectsNY Connects is a state government website that directs New Yorkers to an array of useful services available in their communities. Visitors can use the site's search facilities to find a local provider loaning durable medical equipment free of charge.
New York Program for All-Inclusive Care for the Elderly (PACE)The PACE provider manages all medical and non-medical services in the senior's home or in an adult day care facility or nursing home. PACE combines Medicaid and Medicare services, with the organization responsible for all aspects of care, including the choice of physicians.

Food Assistance Programs

Local organizations help ensure elderly citizens have a balanced diet and receive essential vitamins and minerals to remain healthy. Through nutrition programs, congregate meals, home-delivered meals and food pantries, these programs help New York seniors afford the nutritious food they need.

Program NamePhone NumberDescription
New York Meals on WheelsNew York Meals on Wheels helps connect seniors to food pantries, shared meal sites and home delivery options in their area. MOW volunteers can deliver hot lunches to homebound seniors who are unable to make their own meals, with the food delivery doubling as a welfare check. While program participants are encouraged to support the program with optional donations, there's no financial requirement to participate

Financial Assistance for Senior Living

Low-income elderly individuals in senior living communities can access financial assistance through local-run programs. These New York resources offer advice, guidance and support to help older adults pay for the services offered by long-term care providers.

Program NamePhone NumberDescription
New York Special Needs Assisted Living Voucher Demonstration Program for Persons with DementiaThe SNALR Voucher Program is a demonstration program that helps adults with Alzheimer's disease or dementia pay for care in an assisted living setting. It's designed to prevent enrollment in Medicaid and isn't available to those who are Medicaid-eligible. The vouchers subsidize up to 75% of the average monthly cost for care in the region. Because it's a demonstration program, there is a waitlist for new applicants.

Free Used Medical Equipment

Due to the high cost of purchasing new medical equipment, several organizations in New York collect lightly used medical devices such as wheelchairs, ramps and walkers and distribute them to local seniors and residents in need.

Program NamePhone NumberDescription
New York Technology-Related Assistance for Individuals with Disabilities (TRAID)TRAID is a federally-sponsored program designed to help New Yorkers with disabilities get the equipment they need to live as independently as possible. Local TRAID centers can also refer visitors to other disability related services available in the area.

Health Insurance & Prescription Drug Coverage for Seniors

New York seniors who meet certain income criteria can apply to local resources to help them pay for prescription drugs. Eligible residents can also receive assistance through health insurance and other programs to access free or discounted medical services.

Program NamePhone NumberDescription
New York Elderly Pharmaceutical Insurance Coverage (EPIC) Program800-332-3742The New York Elderly Pharmaceutical Insurance Coverage Program provides secondary coverage for drugs included in Medicare Part D and other approved medications, including prescription vitamins. Additionally, it helps with Medicare Part D premiums for individuals earning under $23,000 annually. To qualify for EPIC, New York residents must be 65+ and not receiving full Medicaid benefits. They must be enrolled in or eligible for Medicare Part D and have income below $75,000. For married couples, the limit is $100,000.

Home Repair and Modifications

Seniors and those with disabilities can access a variety of local resources to help them pay for home repairs and modifications. Programs in New York have different eligibility criteria and often assist retirees by providing grants or loans.

Program NamePhone NumberDescription
New York Residential Emergency Services to Offer (Home) Repairs to the Elderly (RESTORE)New York's Residential Emergency Services To Offer Repairs to the Elderly, known as RESTORE, provides financial assistance to help low-income seniors repair their home. Participants must be at least 60 years of age and meet the income eligibility requirements. They must also own their home, which may be up to a four-unit residence, and reside in the home. RESTORE covers a wide variety of repairs, including structural, plumbing and heating repairs. It also covers modifications to make the home more accessible, such as ramps and grab bars.
New York Weatherization Assistance Program800-342-3009For approved applicants, the program can cover the costs of preparing their homes for changes in season, reducing their energy costs and increasing safety.

Many organizations offer free or low-cost legal services to New York seniors. Older adults can access advice on issues such as estate planning, living wills and power of attorney. Some firms also act as long-term care ombudsmen, advocating for the rights of seniors in senior living communities.

Program NamePhone NumberDescription
New York Office of the State Long Term Care Ombudsman855-582-6769The Office of the State Long Term Care Ombudsman advocates for the rights of Albany's seniors residing in assisted living, memory care, nursing homes and other senior living communities. It acts as a mediator, working with residents, families and care facilities to find mutually beneficial solutions to any issues that arise. The office also provides information and educates seniors and their families on their rights to ensure they live with dignity and a high quality of life.

Senior Centers

Senior centers in New York bring together residents through recreational activities and events. Many also offer advice and support on senior issues, run wellness and nutrition programs, and connect older adults with other resources in the local area.

Program NamePhone NumberDescription
New York State Department of HealthThe New York State Department of Health offers health insurance information and senior advocacy. The department also has free programs for seniors, such as the EISEP program, which allows individuals to access home care services such as personal care at reduced or no cost, depending on their income.

Medicaid Resources

Navigating the Medicaid system is often difficult and confusing. Several New York resources help older adults by providing advice on Medicaid options, waiver programs and eligibility criteria to help seniors receive the right health care benefits.

Program NamePhone NumberDescription
New York Managed Long Term Care (MLTC)866-881-2809MLTC is for existing Medicare beneficiaries, enabling them to continue using services they already receive under that program while covering other home care costs, such as skilled nursing, personal care and home-delivered meals.
New York Assisted Living Program (ALP)518-565-3300New York seniors who are eligible for Medicaid and in need of support in an assisted living setting can apply for the Assisted Living Waiver. For successful applicants, it can cover the costs of some or all of their room and board, emergency response services, occupational therapies and medical supplies and equipment. To qualify, the senior must be able to provide medical evidence that assisted living care is the best option for their needs and that they don't require nursing home levels of support 24/7. The program is limited to 85% of Medicaid recipients, resulting in strict interpretations of the eligibility requirements.

Social Security Offices

Social Security offices in New York help seniors and disabled people access the benefits they're entitled to. Older adults can contact their local office for information about receiving retirement benefits, disability allowance and Supplemental Security Income.

Program NamePhone NumberDescription
New York Social SecuritySocial Security is a source of income available to retirees and people who can no longer work because of a disability. The money for Social Security comes from a payroll tax levied on employers, employees and self-employed individuals. When you retire, you'll receive monthly payments based on how much you earned when you were working.

Tax Assistance

Seniors can apply for tax assistance from several New York resources. Elderly residents and those with disabilities could be eligible for tax exemptions on medical expenses, reductions on property tax and other tax assistance programs.

Program NamePhone NumberDescription
New York Senior Citizen Homeowners' Exemption (SCHE)212-639-9675The exemption reduces the taxable assessment of the qualifying senior's home from anywhere between 5% and 50%, depending on how their local government and school district apply it. Maximum income limits also vary due to location.

Utility & Energy Bill Assistance

Low-income seniors who are struggling to meet the costs of maintaining their homes can find support from organizations that offer assistance with utility and energy bills. New York retirees could also qualify for emergency funding programs if they're in danger of losing utility services due to unpaid invoices.

Program NamePhone NumberDescription
New York Home Energy Assistance Program800-342-3009The program pays one benefit per year to low-income New Yorkers struggling to meet energy costs. There's also an emergency fund existing claimants can request if they're in danger of having their home fuel supply cut off.

Veteran's Services

New York retirees who have served in the U.S. military can find support from local veteran services. These offices and organizations help vets access the benefits they're eligible for and provide advice and information on a variety of issues.

Program NamePhone NumberDescription
New York VA Benefits and Health CareNew York VA Benefits and Health Care includes provisions specific to seniors, offering access to medical and mental health services, as well as help social needs, such as housing and in-home personal care. With major health care systems in Buffalo, Montrose and New York, including community living centers and outpatient clinics, seniors who partook in active service and are now aged 65 and older, have access to a wide range of health and wellness services.

Memory Care Laws and Regulations in New York

The New York State Department of Health licenses and regulates all types of residential adult care facilities, including special needs assisted living residences that provide memory care to individuals with Alzheimer’s, dementia or other cognitive impairments. Adult care facility operators must adhere to all New York laws and regulations pertaining to the rules and responsibilities of these facilities, as highlighted below.

TopicRule
Scope of CareAdult care facility operators must provide an organized, 24-hour a day program of care, supervision and services that includes case management, personal care, meals, housekeeping and social and recreational activities. SNALR operators must also coordinate health care services, offer medication administration and management, and monitor each resident’s condition.
Care Plan RequirementsA written Individualized Service Plan must be developed for each resident upon admission. Plans must be implemented within 30 days of admittance and include the medical, functional, cognitive, rehabilitation, nutritional and other needs of the resident. The plan must also include the type of services that will be provided, how and by whom.
Medication Management RequirementsAll types of adult care facilities may assist with self-administration of medications, including identifying and opening medication bottles, storing medications and prompting residents. In assisted living residences and special needs assisted living residences, only licensed nurses and trained staff may administer medication.
Staff Screening RequirementsAll facility staff must undergo a criminal background check, and staff who have direct contact with patients must be screened for tuberculosis.
Staff Training RequirementsAssisted living and special needs assisted living residences must employ registered nurses, licensed practical nurses and home health aides. Care providers must have graduated from a nursing program approved by the NYS Commissioner of Education or the licensing authority in another state as preparation for practice and have passed the NYS competency examination.
Medicaid CoverageThe Special Needs Assisted Living Voucher Demonstration Program for Persons with Dementia and Assisted Living Program covers a portion of the cost of memory care for those who qualify.
Reporting AbuseAbuse should be reported to the office of the long-term care ombudsman at (855) 582-6769 or ombudsman@aging.ny.gov.

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Caring.com is a leading online destination for caregivers seeking information and support as they care for aging parents, spouses, and other loved ones. We offer thousands of original articles, helpful tools, advice from more than 50 leading experts, a community of caregivers, and a comprehensive directory of caregiving services.

 

The material on this site is for informational purposes only and is not a substitute for legal, financial, professional, or medical advice or diagnosis or treatment. By using our website, you agree to the Terms of Use and Privacy Policy

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