My name is Stephanie Hardy and I live in Stephenson, Virginia. During the pandemic, parents were able to serve as paid caregivers to waiver-eligible minors and we saw a myriad of benefits including less strain on the limited pool of for hire caregivers, family income stabilized as parents didn't risk losing jobs or staying home with zero income to take care of kids with complex needs, and no rise in costs as a parent being the paid provider does not increase access to services already approved. We must reinstate and make permanent these provisions. This proposed amendment - which is consistent with other CMS-approved plans - will make a huge positive difference for impacted families.

With all of that in mind, I am writing today with the following asks:

• Rather than a start date of 01/01/2025, I respectfully ask that this change be backdated to start on 03/01/2024, when the Appendix K waiver expired and new regulations were put into effect. Legally Responsible Individuals (LRIs) who have been providing care in excess of 40 hours per week for more than one waiver-receiving minor ought to be eligible for full reimbursement of approved waiver hours.
• I further ask that consideration be given to how we can extend respite services to LRIs in a manner that is consistent with respite services that can be accessed by patients using the consumer directed option.