General Comments
* DMAS and DBHDS should create the option for a single agency to have one Plan for Supports per individual regardless of the number of services provided to an individual in order to streamline documentation and reduce the number of quarterly reports required. This was a unanimous recommendation of the DBHDS’s own Provider Issues Resolution Workgroup (PIRW) in its report published August 2018.
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* Virginia should develop and implement a central provider audit tool to decrease multiple requests of providers for the same information across reviewers.  This tool should bring together the various monitoring entities and result in collaboration and consistency in interpretation across agencies and reviewers eliminating redundancy in documentation requests. This includes reviews by DBHDS subcontractors, human rights, licensing and Medicaid regulations and interpretations by contractors, specialists, quality management and provider integrity.

12VAC30-122-20. Definitions. General:
* Positive Behavior Supports – use the definition of the American Association for Positive Behavior Supports and delete the language provided. This will bring the service in line with the national standard.
* Supported living residential- delete following a service “taking place in an apartment setting”; add following operated by a DBHDS-licensed provider. Change to “taking place in an individual’s own home”. There is no operational reason to limit the choice of the type of living arrangement.
12VAC30-122-60. Financial eligibility standards for individuals.
* B.3.a.(1) and B.3.b.(1) Delete following employed “at least 8 hours but”. Individuals who work fewer than eight hours per week are unnecessarily disadvantaged by the limitation. Many individuals may work less than 8 hours per week because of medical or other reasons. Without this disregard, there is no incentive for them to work because their income would go to patient pay.
* Recommend Special Group Category Consideration – SSI/SSDI waiver recipients increasingly have retired, disabled or deceased parents and the waiver recipient’s income increases because their parent’s FICA account is opened and a portion of this account is received by the waiver recipient.  This amount (now SSDI) often puts the waiver recipient over the 300% gross income limit. The first thing the individual does is quit work if working. These individuals should be put in a “protected category” which will disregard the amount of the new income (SSDI) that will cause them to become ineligible for waiver services. This protection is considered when looking at continued Medicaid eligibility.  (https://secure.ssa.gov/poms.nsf/Inx/0501715015)

12VAC30-122-90. Waiting list; criteria; slot assignment; emergency access; reserve slots.
* C.1.a. – Following care for the individual   add “a primary care giver who is 70 years of age or greater”. While we recognize that the age criterion was removed during the “redesign,” we feel that the impact has been significant on older families. It also limits the family’s ability to assist their adult children to make life decisions before it is an emergency.
* C.1.a- Following there are no strike “other”

* C.1.b.(2)- Following managed strike “by the primary caregiver”

12VAC30-122-120. Provider requirements.
* A.10.d- Strike “Such documentation shall be written on the date of service delivery.” This is not in keeping with the definition of Progress Note in 122-20 and as referenced earlier in comments.