Virginia Regulatory Town Hall
Department of Medical Assistance Services
Board of Medical Assistance Services
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9/28/22  5:29 pm
Commenter: Kimberly Black, Hope House Foundation

Chp. 2 & 4 HHF Public Comments

Chapter 2


  • Although adverse action is defined in chapter 2 of the DD manual, a listing of adverse actions should be documented to provide guidance on when the appeals process is applicable. A claim denial is an adverse action that must be appealed in 30 days from the date of the remittance advice.  However, providers do have the year period from the date of service to bill and adjust the claim. This nuance is not clear when reading the manual.


Chapter 4

General Comments

Clarity surrounding when a provider should upload an updated Part V to WAMs would be helpful (i.e. every time there is an update or only when certain circumstances apply)

Supports Intensity Scale

  • The Virginia Supplemental Questions used to identify individuals who have unique needs falling outside of needs identifiable using the SIS does not specify the description of a Level 5 assignment, only ‘maximum support needs’ is stated. Level 6 is further described as ‘Intense and Significant Medical’ and Level 7 is further described as ‘Intense and Significant Behavioral’

Therapeutic Consultation

  • Include PBSF, LPC and LSCW as members able to provide billable therapeutic consultation services.
  • Clarification on BCBA and BCABA (BCBA assistant) and roles of each should be included. Can BCABA provide TC service independently without supervision from a BCBA?
  • Specify which members are included in the physical therapy disciplines.
  • A ‘therapeutic consultation support plan’ is the assessment-based report of recommendations resulting from a TC that is developed by the professional consultant after the professional consultant spends time with the individual to determine the individual’s needs in the professional consultants expertise area.
  • This service should be covered in the BI waiver as well.
  • Completion of progress notes are required by regulation but considered ‘in kind’. Any documentation relevant and necessary to the plan should not be considered ‘in kind’.
CommentID: 162226