12VAC30-50-440 and 12VAC30-50-490 outline expectations and requirements for Support Coordination differently for those with a diagnosed Intellectual Disability (440) and those with a diagnosed Developmental Disability (490) despite the merger of the ID and DD Waivers. It would seem that the the requirements for Support Coordination providers, definitions of the service and knowledge, skills and abilities would be the same. These sections of the regulations do not align and show there is a disparity in the service and expectations depending on the individuals diagnosis. 

12VAC30-50-490 A2. discusses placement on wait list for individuals with DD diagnosis whereas this is not referenced for individuals with ID diagnosis in 12VA30-50-440. Individuals are placed on the waitlist regardless of diagnosis when slots are not available.

These sections also allow for individuals with ID and DD diagnosis to recieve Support Coordination services while on the Waiver wait list but makes it time limited and more restrictive for individuals with DD diagnosis. With DD and ID systems merged there is nothing of which I am aware that would show that individuals with DD diagnoses would not have the same need for SPO Support Coordination as those with ID diagnoses. 

Support Coordinator qualifications should allow an option for entry level Support Coordinators who posess a Human Services degree but lack the experience to provide services under a QDDP to gain the required experience similar to QMHP-Eligible. 

12VAC30-50-450 F1b1 should acknowledge that the CSB can provide choice of Support Coordinators as available. There are many factors in determining SC availabilty such as specialized duties and caseload size. 

There also needs to be considered that individuals may choose to select (or remain with) a CSB that is geographically too far to effectively provide Support Coordination. 

12VAC30-122-20 Definitions exclude a definition for Intellectual Disability. 

12VAC30-122-50 A1. Cites definition of devlopmental disability 37.2-100. In that section of the Code there are two separate definitions, one for Developmental Disability and one for ID. Is the language in this and following sections now referring to just DD or DD and ID? This section also states indviduals must be at risk of institutionalization. This language appears outdated and unrealistic as in present day individuals would find it extremely difficult to be "institutionalized" even if that was their preference. 

12VAC30-122-80. H. Providing choice of institutional vs. community placemnt is currently performed by DBHDS staff, not the CSB/BHA.

12VAC50-122-80.C7b. Does developmental disability refer to DD or ID or both as the code referenced differentiates.

12VAC50-122-90. A. Same question as above regarding DD, or ID or both.

12VAC50-122-530. Sponsored residential section should address when it is allowable or if it is allowable for family members/guardians to serve as the sponsor. There is language regarding family as service provider under Consumer Directed services but not in this section.