Amendment 2. - While this change "could" be beneficial, what is the negative impact, particularly among those who are actively waiting for a Priority 1 CL waiver slot? These individuals are in desperate need of high-level services, so extending a waiting period of up to one year would further delay their access to critically necessary/needed services and supports.

Amendment 3. - Medicaid waiver long-term services and supports are critical for individuals receiving waiver services. This amendment will improve ease of access to this lifeline for individuals with disabilities. This amendment will eliminate the penalty for recipients of SSDI.

Amendment 4. - Removing parents as providers would be profoundly damaging, particularly to the well-being of medically complex or disabled children. They should be a first resort, not last. Parents are not just caregivers; they are the most knowledgeable and invested providers in the individual's care, having dedicated themselves to understanding and meeting the individuals' unique needs. Stripping them of this role would disrupt the continuity and quality of care for the most vulnerable of populations.

Moreover, no alternative provider can replicate the deep, personal commitment and intimate understanding that parents bring to the care of individuals served. The emotional security, trust, and consistency that a parent provides is irreplaceable and essential for the individual's overall development and wellbeing.

In essence, removing parents from their role as providers would undermine the very foundation of care that individuals can thrive from, leading to potentially severe and irreversible consequences.

Additionally, compensating parents for their caregiving is not only equitable, but also economically advantageous. The cost to the state is significantly lower when parents are reimbursed, as opposed to the higher fees demanded by nursing agencies and home health providers.

Further, not allowing individuals to choose a provider, even if that provider is a parent or guardian, would directly violate their human rights and right to choose, as outlined in DBHDS regulation and HCBS Federal regulation.

Lastly, the new regulations for LRI caregivers, recently enacted by Virginia's General Assembly and endorsed by Governor Youngkin, must be implemented by DMAS, as prescribed in the legislation.

Amendment 6. - The educational requirements that exist (a Bachelor's degree) are imperative in consumer-directed services. Under the agency-directed services model, a RN is required to complete the same paperwork that is completed under the consumer-directed model by a service facilitator (DMAS 97AB plan of care, DMAS-99 assessment, etc.) and removing the educational requirement would essentially be saying that requiring the education level of a registered nurse in one model, requires no education in another. The consumer-directed models are already significantly under-regulated, and removing the educational requirement would only further increase the risk for fraud, inconsistency, and errors in paperwork.