Virginia Regulatory Town Hall
Department of Medical Assistance Services
Board of Medical Assistance Services
Waivered Services [12 VAC 30 ‑ 120]
Action Omnibus Waiver Regulatory Changes
Comment Period Ended on 7/9/2008
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7/7/08  3:31 pm
Commenter: David Shue, Harrisonburg-Rockingham Community Services Board

Comments on the NOIRA for Omnibus Waiver Services

Comments from Harrisonburg-Rockingham Community Services Board, Harrisonburg, VA

(David Shue, Director of Community Support Services) – July 7, 2008


We appreciate the intent of streamlining the various DMAS waivers.


We oppose inclusion of the MR Waiver and the MR Day Support Waiver in a consolidated package for the following reasons:


-                     There are unique and significant features that have been specifically designed to meet the unique needs of individuals with mental retardation (or intellectual disability). 

-                     Unique features have been crafted and refined over many years through excellent collaboration of CSBs, DMAS, advocates, and in full sight of the General Assembly.  The waivers may not be simple, but they work because they have been carefully crafted.

-                     Expertise in mental retardation is strongest at DMHMRSAS and, locally, at CSBs.  The role of MR case managers is critical, and again has been developed and refined over a period of years through collaborative processes.

-                     Oversight of waiver services is strengthened by the partnership of DMAS and DMHMRSAS.

-                     Inconsistencies, while often troublesome, are in this case the reflection of necessary attention to the unique needs of Virginia’s participants in the MR Waiver and MR Day Support Waiver.


Thank you for the opportunity to comment.

CommentID: 1819