Moms In Motion has thoroughly reviewed the CCC+ application that is out for public comment currently.  The following are our comments:

All throughout the application, the word “provider” is used interchangeably to mean either Paid Attendant or Provider Organization.  The language needs to be altered throughout the application to purposefully distinguish between the two.

SF Educational Requirement - On page 42, 2nd paragraph, the language still contains the requirements for Service Facilitators to have an Associate’s or Bachelor’s degree.  This requirement was removed by the General Assembly this past session via Item 288.CCCCC (2024).   The educational requirement for Services Facilitators needs to be removed from this application.  A degree does not necessarily make a person a better Service Facilitator.  We would argue that compassion and experience are what is needed to make someone a great Service Facilitator.  In fact, the requirement for the degree exacerbates the workforce crisis for providers, especially in more rural areas of the state.  It was added to regulation back in 2016, but no additional reimbursement rate increase was provided to cover the increased cost to employ someone with a higher education.  Per the direction of the General Assembly, please remove this requirement in this application. 

Definition of EOR - On page 62, last paragraph, the language has changed around who can be the EOR if the individual is unable to independently manage his/her own CD services, or if the individual is under 18.  The current Regs (12VAC30-120-900. Definitions) say this, “"Employer of record" or "EOR" means the person who performs the functions of the employer in the consumer-directed model of service delivery. The EOR may be the individual enrolled in the waiver, a family member, caregiver, or another person.  In this application, that is being changed to “a spouse, guardian, adult child or parent of a minor child must serve as the employer on behalf of the individual.”  There was no regulatory change made by the Generally Assembly during this past session to modify the definition of the EOR.  By making this change in this application, an individual’s right to choose a friend or neighbor to be their EOR is being removed.  This language needs to be restored to the current regulation language to include “another person” so that the right of the individual to choose whomever they would like stays in place.

SF Educational Requirement - On page 110, last paragraph, it says, “The Services Facilitator must possess a combination of relevant education and work experience….”.  This requirement was removed by the General Assembly this past session via Item 288.CCCCC (2024).   The educational requirement for Services Facilitators needs to be removed from this application.

Definition of EOR - On page 138, 5th paragraph, once again the language is changing the definition of an EOR, and in this instance, it doesn’t even match the definition on page 62 of the application.  On page 138, the application says, “If the individual is interested in self- direction but is unable to independently manage his/her own CD services, or if the individual is under 18 years of age, a parent of a minor child or responsible adult must serve as the employer on behalf of the individual.”  The general assembly gave no direction to change this definition.  This language needs to be restored to the original definition of an EOR so that it is consistent.