Emily McClellan, Regulatory Manager

Division of Policy and Research

600 E. Broad St., Suite 1300

Richmond, 23219

RE: 2015 Long Term Services and Supports Screening Changes

Dear Ms. McClellan,

disAbility Law Center of Virginia (dLCV), the Commonwealth’s designated protection and advocacy system for Virginians with disabilities, appreciates the opportunity to comment on the 2015 Long Term Services and Supports Screening Changes.

The majority of the changes appear to provide adequate oversight of the service delivery process to protect the rights of the service recipients. dLCV is disappointed however, that DMAS is not taking advantage of the opportunity in 12VAC30-60-303 to offer better protections to nursing facility residents by limiting the use of chemical and physical restraint. We hope that DMAS will consider revisiting reducing allowable restraint practices in future policy. dLCV requests participation in those discussions when they occur.

Sincerely,

Colleen Miller

Executive Director

dLCV