|Action||Omnibus Waiver Regulatory Changes|
|Comment Period||Ends 7/9/2008|
SUBJECT: VACSB Comments Regarding NOIRA to Publish Omnibus Waiver Regulations
On behalf of the Virginia Association of Community Services Boards (VACSB), thank you for the opportunity to comment upon the intention of DMAS to publish Omnibus Waiver Regulations.
The VACSB appreciates the intention to streamline regulations; however, it is our strong and enduring belief that, while there may be some cause for certain components of the Regulations to be consolidated, the MR Waiver and MR Day Support Waiver regulations should remain entirely separate beginning with 12 VAC 30-120-211 through 12 VAC 30-120-249 and 12 VAC 30-120- 1500 through 12 VAC 30-120-1550.
The VACSB has been an active and critical participant in the development, design, implementation, and revisions of the MR Waiver and, more recently, the MR Day Support Waiver. These Waivers have many unique and significant features that must be retained. Additionally, these two Waivers have figured highly in public policy discussions and decisions made by
The MR Waiver, at the direction of the General Assembly and the Administration, was developed by DMHMRSAS, in consultation with CSBs, DMAS, and advocates. Within DMHMRSAS resided the experience and leadership for services for persons with Mental Retardation. As a result, the MR Waiver was intended to offer services and supports for people with Mental Retardation who could and chose to live in their communities and was based upon the best expertise and knowledge of the needs of individuals with Mental Retardation. The history of its development, oversight, and implementation, all of which occurred in the public eye and was the focus of two important legislative subcommittees, is too lengthy to describe in these comments. The results of this history constitute the reasons why these Waivers should be entirely separate:
Thank you again for this opportunity.