Virginia Regulatory Town Hall
Agency
Department of Medical Assistance Services
 
Board
Board of Medical Assistance Services
 
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9/6/24  11:33 am
Commenter: Anonymous

HB909/SB488 (2024)
 

The proposed changes to the CCC+ waiver, which would reintroduce the need for extensive documentation, need to be reconsidered. These rules fail to acknowledge the real-life struggles of families, and they erect unnecessary hurdles without enhancing the quality of care for children.

Consider a parent caring for a child with a disability who requires constant attention. This parent already manages all the daily caregiving tasks, medical appointments, and therapies. If they are also required to submit a mountain of paperwork, such as medical records, doctor’s notes, and detailed logs of their caregiving, it would consume hours that could be spent caring for their child. Moreover, this paperwork could delay approval for crucial services, leaving the child without the necessary support. This approach only adds to the caregiver's burden without benefiting the child.

These excessive documentation demands fail to acknowledge that the parent, as the Legally Responsible Individual (LRI), is often the most capable and experienced caregiver. Instead of simplifying the process, it complicates caregiving and delays care. This unnecessary stress on families not only diminishes the child's quality of care but also leaves caregivers feeling overwhelmed and unsupported.

Families should not be forced to navigate through a maze of paperwork to care for their children. Requiring these documents only serves to harm the very people the system is designed to assist. We, as a collective, stand in opposition to these amendments and firmly believe that the focus should be on supporting caregivers, not adding to their workload.

Keeping the parent, or LRI, as the first choice to provide care is critical. They understand the child’s needs better than anyone else, and removing or restricting this option could harm the child by delaying care and reducing the quality of support they receive. For this reason, I strongly oppose the Application for 1915(c) HCBS Waiver: Draft VA.004.05.03. If this waiver is approved, it would take away the necessary flexibility and security that families depend on, putting children at risk.

CommentID: 227699