|Action||Three Waivers (ID, DD, DS) Redesign|
|Comment Period||Ends 4/5/2019|
Section 12VAC30-50-490 (E) Qualifications of Providers, Number 3: States:
3. Support coordination/case management services shall not be provided to the individual by: (i) parents, guardians, spouses, or any family living with the individual, or (ii) parents, guardians, spouses, or any family employed by an organization that provides support coordination/case management for the individual except in cases where the family member was employed by the case management entity prior to implementation of these regulations.
I would like to express my concern that the final statement in this clause (ii), originally introduced in the emergency regs and redefined here, creates a hardship for the individuals with ID/DD who live in rural or semi-rural areas where there is little to no choice of case management providers. In many areas of the state, there may be only one CSB within a reasonal driving distance. 12VAC30-50-490 also clearly states that individuals with ID/DD have the right to chose their case management provider, but if that individual has a family member who works for the local CSB in any capacity (mental health, early intervention, ID/DD services, etc), the main provider for ID/DD case management is eliminated as a choice for that individual.
The inital part of this regulation (i), stating that support coordination should not be provided by family members of an individual, should be sufficient in ensuring authentic and ethical service delivery. Please consider removing (ii) to ensure that all individuals with ID/DD have sufficient choice in case management regardless of where their family members are employed.