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The proposed amendments to the CCC+ waiver should be reconsidered. Requiring parents to repeatedly prove their qualifications through excessive documentation imposes unnecessary burdens, diverts valuable time away from direct caregiving, and devalues the role of parents as knowledgeable and deeply committed caregivers, without enhancing the quality of care.

The economic sacrifices made by family caregivers are well-documented. Given their deep commitment to meeting their children's unique needs, parents often provide care regardless of compensation. However, knowing that parents will provide care does not justify normalizing or codifying this burden—especially when reimbursing parents is more cost-effective for the state than relying on more expensive nursing agencies and home health providers.

I strongly oppose the Application for 1915(c) HCBS Waiver: Draft VA.004.05.03, as the proposed changes would remove essential support, undermine individuals' rights to choose their care providers, and burden Legally Responsible Individuals (LRIs) with unnecessary bureaucracy. Lawmakers should prioritize supporting caregivers to ensure the best outcomes for children and their families.

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