As a parent of a child enrolled in the CCC+ waiver program, I’m deeply concerned about HB909/SB488 (2024), which proposes reverting to the previous system requiring extensive documentation for The Objective Written Documentation Form. I’ve had firsthand experience navigating this process and found it an unnecessary administrative burden. The time and effort spent collecting and submitting documentation significantly detracts from the time spent providing critical care to my child. This situation stresses families like mine and delays receiving essential services. The personal toll of this bureaucratic process on my family is immense, and I fear the proposed changes will only exacerbate this.

The critical challenge of the proposed amendments is reintroducing the requirement for exhaustive supporting documentation. This adds a bureaucratic layer that complicates rather than supports the caregiver's role, creating delays in care and imposing unnecessary administrative burdens on already overworked families. Requiring detailed documentation—such as medical records, assessments, and care logs—places significant strain on caregivers and leads to service delays, which can be detrimental to the child’s well-being.The urgency of this issue cannot be overstated.

Consider the case of a parent caring for a child with complex medical needs. The parent must manage daily care, appointments, and therapy sessions while maintaining a stable home environment. Under the proposed changes, this parent would also be required to gather extensive documentation to justify their role as the primary caregiver. This burden of proof, in the form of logs, medical evaluations, and written reports, shifts focus away from caregiving and onto paperwork. Moreover, submitting and waiting for approval delays access to crucial services, directly impacting the child’s progress and quality of life. The potential harm to the child's well-being is a grave concern, and these changes must be reconsidered.

The impact of these changes is significant. Caregivers, often the most knowledgeable about their child’s needs, face unnecessary administrative obstacles, leading to delays in receiving services. This can harm the child by disrupting the continuity of care and causing potential setbacks in their development. Instead of streamlining support for families, these documentation requirements introduce inefficiencies and create additional challenges for caregivers. By placing more administrative hurdles in the way, the system risks worsening the issues it aims to address, and the responsibility for this potential harm lies with the decision-makers.

The Legally Responsible Individual (LRI) must remain the primary and first option for providing care. As the individual most familiar with the child’s needs, the LRI is uniquely positioned to ensure continuity and quality of care. Any amendments that limit or impose unnecessary barriers to this role would harm the caregiver and, more importantly, the child. Therefore, I strongly oppose the Application for 1915(c) HCBS Waiver: Draft VA.004.05.03, as it would create more harm than benefit by reducing flexibility and adding undue stress to families who rely on the system for support. I urge you to reconsider these changes and maintain the current system that provides the necessary flexibility and support for families like mine.