The proposed amendments related to the CCC+ waiver, which would reinstate the requirement for exhaustive supporting documentation, are fundamentally flawed and counterproductive. These changes overlook the practical realities caregivers face and impose unnecessary administrative barriers that do not contribute to better outcomes for the child.

Consider the case of a parent caring for a medically complex child who requires round-the-clock care. Under the current system, this parent must gather and submit an extensive array of documents—from medical records and care plans to professional assessments—to justify their role as the most suitable caregiver. This burdensome process not only consumes valuable time but also delays service authorization. Rather than streamlining access to essential care, this requirement places an undue strain on families already managing a highly demanding situation. Forcing parents to repeatedly prove their qualifications, despite the clear benefits of maintaining continuity in care, creates a counterproductive administrative cycle.

These excessive documentation requirements need to recognize the unique position of the Legally Responsible Individual (LRI) as the most knowledgeable and capable person to provide care. Instead, they subject caregivers to an unnecessarily bureaucratic process that diverts attention and resources from the child. This additional burden is inefficient and harmful, as it delays access to critical services and exacerbates caregiver burnout, ultimately impacting the quality of care provided.

 Opposition to these amendments is not only about reducing administrative burden but also about ensuring that families can focus on what truly matters—the care and development of their children. Returning to a system that prioritizes paperwork over practical caregiving solutions is not in the best interest of the child or the family.

Retaining the LRI as the first option for personal care services is crucial. The LRI often understands the child’s needs and is best positioned to provide consistent, individualized care. Any amendment that disrupts this arrangement would create unnecessary delays in service delivery and result in suboptimal care, causing significant harm to the child. This is why I strongly oppose the Application for 1915(c) HCBS Waiver: Draft VA.004.05.03, as it would erode the flexibility and support families rely on, leading to adverse outcomes for caregivers and their children.