12VAC35-105-20:

The word “training” has been redacted throughout the draft amendments but not consistently.  Consider removing this word throughout the regulations

Day support & ADL’s – remove the word “toileting”

Group Home – Will providers currently living in the home be grandfathered in under this revised regulation?

QDDP –This definition does not match the Medicaid definition. Consider revising so the  definitions line up.

Services – The likelihood of ameliorating a developmental disability is unlikely.

Serious injury - means any injury resulting in bodily hurt, damage, harm … Please define bodily hurt and how this is different than harm or damage.

 12VAC35-105-160:

D. Reporting clarification needs to occur to identify that only the responsible provider at the time of the incident is responsible for reporting (internally and in the CHRIS System).  Please clearly state this.

D.2. Consider adding language to include contacting the SC when a Level II or III Serious Incident have occurred.

 12VAC35-105-590:

C.9, F. Brain injury services is not defined.  Will providers supporting people who have TBI but receive supports under the DD Waiver because of the age of their injury be held to these standards?

 12VAC35-105-660:

B. The language makes it sound like a 60 day plan is required when initiating a new services which has never been the case before.  Please consider revising the language to say “may develop and implement” instead of “shall develop and implement”

C. The language makes it sound like it is the responsibility of all providers to complete this task when it is the really the responsibility of the support coordinator for DD services.  Consider revising the language to reflect this.

 12VAC35-105-675:

D. Consider adding language to address the allowable 10 day grace period for providers to complete their quarterly and 30 days for the support coordinator to complete their quarterly in order to align with the long-standing DMAS policy.

D.3. Consider removing the requirement that the team must meet every time a target date is not met. This will create a burden on the planning team or will create a trend of only annual goals being set.