12VAC30-50-490 – C9 Support coordinator shall complete a minimum of 8 hours training annually.

 Does this need to be DBHDS training or can it be obtained elsewhere?  Needs clarification.

12VAC30-50-490 – F2 The individual may have his choice of support coordinator/case manager employed by the CSB or BHA. 

This should read that they have their choice of another CM if dissatisfied with services.  Being able to hand pick a CM may not be feasible because of caseloads or other circumstances.

12VAC30-50-490 – C7 Supervision

It reads as if the support coordinator needs a degree; however the supervisor is not required to have a degree?

12VAC30-122-40 –A The FIS, CL, and BI Waiver services….shall not be authorized or reimbursed by DMAS for an individual who resides outside of the physical boundaries of the Commonwealth.

                This should apply to those on the waiting list as well.

12VAC30-122-90 – Hc CSB’s or BHA’s shall document and notify DBHDS…..The Assignment of reserve slots shall be managed by DBHDS, which will maintain a chronological list of individuals in need of a reserve slot in the event that the reserve slot supply is exhausted.

Individuals requesting a reserve slot should be included in the pool being considered for vacated slots and that the WSAC should be the only entity that awards waiver slots.

12VAC30-122-120 –A10d – Providers shall prepare and maintain unique person-centered progress note written documentation…..Such documentation shall be written on the date of service delivery.

                Suggesting a longer grace period for progress note writing.

12VAC30-122-90 – Wait list

                Request that age of care giver continue to be a factor.

12VAC30-122-80 – 5b – DBHDS and slot retention

                Need clarification if eligibility is defined by the VIDES or if it is a financial issue (Medicaid).

12VAC30-122-100- D Termination in a non-emergency situation

                Request that 30 day notice is given instead of 10.

12VAC30-50-440 – A1 – An active individual….at least one face-to-face contact every 90 days.

Current DMAS regulations allow a 10 day grace period in addition to the 90 days.  Suggest continuing with the grace period.

Proposed regulations do not address having parents as the last resort for sponsored placement.  It is currently addressed in the DMAS manual (briefly).  It should have a clear definition of expectations and allowable activities in these regulations.