Virginia Regulatory Town Hall
Department of Medical Assistance Services
Board of Medical Assistance Services
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9/1/22  2:16 pm
Commenter: Moms In Motion/At Home Your Way

Allow Telehealth as a permanent delivery method for ALL SERVICES
Please find below the Moms In Motion public comment regarding the Amendment that DMAS is submitting to CMS to allow Telehealth as a permanent delivery method after the PHE has ended:
In the General Assembly budget language the following is written:
313.DDDDDD. The Department of Medical Assistance Services, in coordination with the Department of Behavioral Health and Developmental Services, shall submit a request to the Centers for Medicare and Medicaid Services to amend its 1915(c) Home & Community-Based Services (HCBS) waivers to allow telehealth and virtual and/or distance learning as a permanent service option and accommodation for individuals on the Community Living, Family and Individual Services and Building Independence Waivers. The amendment, at a minimum, shall include all services currently authorized for telehealth and virtual options during the COVID-19 pandemic. The departments shall actively work with the established Developmental Disability Waiver Advisory Committee and other appropriate stakeholders in the development of the amendment including service elements and rated defined methodologies. The department shall have the authority to implement these changes prior to the completion of the regulatory process.
This language was passed as it is written above by the General Assembly.  Therefore, we submit that DMAS is misrepresenting the fact that they have included Service Facilitation in their amendment by ONLY including 1 of our 5 services.  Management Training, which is the only service under SF that was included in this draft amendment, is not typically a stand alone service.  It is usually done in conjunction with a Routine or Reassessment visit when the EOR requests retraining during a visit.  Therefore, the reality of the amendment the way it is written is that DMAS has not included Service Facilitation at all in its request to continue to allow Telehealth as a delivery method after the PHE has ended.  
All of the services (as stated in the budget language) should be included in the amendment.  Let CMS decide which, if any, need to be removed. 
CommentID: 128497