Virginia Regulatory Town Hall
Agency
Department of Medical Assistance Services
 
Board
Board of Medical Assistance Services
 
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8/29/24  3:46 pm
Commenter: Anonymous

Comments on Certain Proposed Revisions
 

Combining the annual service limits for Assistive Technology and Electronic Home-Based Services into one annual $10,000 limit to be shared between the two services. (BI, CL, FIS)

Yes absolutely, as combining the annual service limits would increase the amount of funding available to the individual. Considering the cost of everything in 2024, it has become more and more difficult for people to sustain themselves, much less pay for extraordinary care/accommodations and services.  

Permit the allowance for individuals offered a Developmental Disabilities Waiver slot to delay enrollment into the waiver for up to 1 year. (BI, CL, FIS)

Yes absolutely. There is a clear disconnect between disabled people and the availability of service providers. Service providers struggle to find adequate staffing which keeps people from getting the services they need. There is a severe deficit in the disability workforce. There must be some sort of incentive involved to attract new workers into the field. Having bodies to fill jobs isn't enough. We are suffering a workforce crisis where there needs to be changes made to attract highly skilled, highly qualified individuals to care for our most vulnerable members of society. As it currently stands, there are little incentives to attract new hires into the field and the disabled person should not have to worry about losing their waiver slot because services are unavailable or out of reach. These people, and those who care for them already have enough to worry about simply trying to survive with the limited resources available to them. 

Disregard Social Security Disability Insurance (SSDI) benefits above the maximum Social Security Insurance (SSI) benefit limit as determined by the Social Security Administration for purposes of pre-eligibility treatment of income. (BI, CL, FIS)

Yes absolutely. It's 2024. EVERYTHING is super expensive these days. The current cap for SSI itself is too low, and does not cover an individual's rent, much less utilities and necessary daily expenses. The fact someone is receiving SSDI should not determine eligibility if their basic living expenses are not being met.  

Amend the rules for when a Legally Responsible Individual (spouse or parent of a minor) is a paid aide/attendant for personal care/personal assistance. (CL, FIS, CCC+)

Paid parent caregivers are inherently a disabled person's first line of defense in a world that is absolutely apathetic to the struggles of trying to sustain themselves and their families. On top of trying to sustain themselves, it is up to that parent to advocate for the services the child needs, the medical care the child needs, and any behavioral interventions the child needs in order to prepare that child to sustain themselves (if at all possible) as an adult. A parent should not have to decide whether or not they should put the child first or put the livelihood and well-being of the entire family unit first. Many of these parents have been disenfranchised from the workforce, by no fault of their own. For many, it is impossible to maintain a schedule working full-time to sustain the family AND implement a full-time schedule of caring for their disabled child. Many of these children require round-the-clock care and supervision. Oftentimes, they are members of single parent households due to the high rate of divorce among the parents of those with ID/DD children. Just today, the Surgeon General put out a warning regarding the dangerous levels of stress parents are enduring. Add to the mix the stress of trying to care for a disabled person at home, while juggling a 40-hour per week job, AND meet that disabled person's needs, while trying to sustain your household. The stress level at that point becomes insurmountable. In households where there are two parents, many choose to sacrifice the income of one parent so they can stay home with the ID/DD individual. This significantly decreases the family income. Further, the current pay to hire a PCA is extremely low and offers no benefits whatsoever outside of PTO. Hiring someone at the current rate becomes near impossible when the pay rate to perform the duties of being a PCA is so ridiculously inadequate and unsustainable.

Further, prior to the General Assembly passing the law allowing LRIs to permanently become PCAs for their disabled children, people were scrambling to provide objective written documentation (OWD) in efforts to prove they were the providers of last resort. COUNTLESS individuals across the state were posting ads on social media and other public forums disclosing personal and confidential details regarding the care of the child. I found this practice abhorrent as it appeared it would be in violation of HIPAA, should anyone else but the parent disclose these details. Public posts were made regarding g-tubes, picc lines, incontinence, behavioral outbursts and meltdowns. Realities no one wants to have to endure, yet disclosed in the spirit of transparency. Parents wanted their applicants to know exactly what they'd be dealing with. Many were accused of trying to deter applicants with their disclosures. Many applicants verbally assaulted and insulted some of these parents due to the level of expectation required for the job and the low pay. The OWD requirement needs to be removed. LRIs/Parents MUST be allowed to permanently be paid for their disabled children as a first choice.

 

Add nursing facilities and Program for the All-Inclusive Care for the Elderly (PACE) providers to screen individuals in the community for waiver enrollment (CCC+)

Why is this not already a thing? The screening tool is the same - the UAI. It only makes sense they should cross over.

Remove educational requirements for Services Facilitation providers (CL, FIS, CCC+)

Although it is of the utmost importance for Service Facilitation providers to be able to hire and train highly skilled and educated professionals to perform their duties, having such a strict degree requirement policy eliminates MANY potential job candidates who are well equipped to perform this job. Consider the fact Moms In Motion - Virginia's largest service facilitation provider was founded by mothers of disabled children trying to navigate their way through the sea of confusion to obtain services and supports for their children. There are many of those out there whose life circumstances cut their college matriculation short. Oftentimes, the birth of a disabled child plays a role. The degree requirements should be eased by stating a combination of education and/or experience should be necessary. It should be up to the service facilitation company to be able to screen and hire the absolute BEST candidates regardless of their educational background. Easing the degree requirement would open up doors for both the candidates who desire (or even NEED) to work in this field, as well as the service facilitators who struggle to attract candidates into their hiring pools. 

CommentID: 227493