The Virginia Board for People with Disabilities will be submitting public comment on the proposed Omnibus regulation during the formal public comment period after the draft regulations are published.  We hope that there will be significant stakeholder involvement during the development of the draft regulations.  The Board also hopes that any proposed regulatory changes in definitions or related to service provision will be focused on ensuring person centered practices and maximum flexibility for consumers and families.  The goal of any regulatory changes should be to “do no harm.”  The Board would be very concerned with any proposed changes that weaken rather than strengthen consumer direction or which move the Commonwealth backward to a more medical vs. consumer directed model of services, including what appear to be potential new excessive credentialing requirements for service facilitators (i.e., having a nursing credential),  If an Omnibus regulation continues to be pursued, the focus should be solely on coming into compliance with any specific CMS requirements or corrective action requests and on providing consistency in financial agreements, terminology and definitions which vary from one waiver to another.  Identical services available under more than one waiver should be defined in the same manner and the same set of rules should apply to those services.  If for example, an individual transitions from one HCBS Waiver to another they should be able to maintain a service in the manner in which they are currently using it and maintain their providers without having to wade through confusing and differing requirements--other than those requirements that are uniquely specific to the Waiver itself (such as eligibility, alternate institutional placement, or entirely different services), etc. The Board understands the need for regulatory review of waivers, but hopes that time and effort will also be devoted to development of a plan to improve and expand waiver services, including expanding consumer directed options, improving information available to consumers and families, improving the administration of consumer directed payroll services, and enhancing quality control mechanisms.