Virginia Regulatory Town Hall
Department of Medical Assistance Services
Board of Medical Assistance Services
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3/23/23  7:29 pm
Commenter: Christine Perry

Support families instead of complicating our lives

Virginia was cited in the MACPAC( Advising Congress on Medicaid and CHIP Policy) Congressional Brief in March 2022.  This brief by a Federal Government Agency  that exists to report to the US Congress is titled “State Effort to Address Medicaid Home and Community-Based Services Workforce Shortages”.  On page 8 of the brief it states “For example, Virginia’s 1915 (b)/(c) program allows for self-direction including paying family caregivers.  During the COVID 19 pandemic, the state expanded who can be paid as a caregiver to include spouses and parents of minors”.  This brief also cites that there is a workforce shortage nationwide and highlights the drivers of this as low wages, limited opportunities for career advancement and high turnover.  

In spite of this knowledge, both DMAS and DBHDS are now “enforcing” a stipulation in the waivers that there must be “objective documentation that demonstrates that there are no other persons available to provide supports to the individual other than the unpaid family/caregiver who lives in the home with the individual".  This had previously not been an issue with yearly plan approvals, but agencies have been notified in the last few months to “enforce this documentation”. I am on a Virginia Medicaid Waiver Discussion Group.  I see posts daily where families are distressed by their loved one’s plan being “pended” to provide “objective documentation”.   WHY?  You already know that there is a workforce issue nationwide and that it is very difficult to find competent care for our most vulnerable loved ones for $12.70 per hour which is barely above minimum wage.  They pay more at fast food restaurants.  Yet, you want us to “scrounge around” to try to find someone outside of the home to care for our loved one, when we are the ones that know them best and can best meet their needs. IDD individuals need stability. In particular, those with autism have major issues with changes in routine.   High turnover, if you can even find a competent worker, create lots of distress for the IDD individual and for the families.  You should be supporting families that care for their loved ones, not making things more difficult and making us jump through “bureaucratic hoops” .  Parents of minors and spouses should not have to be employed by an agency, but should be consumer directed. 

My son is #14 on the list for a day program, and this program is 20 miles each way from our home.  He’s been #14 for a year and has not moved up on the list.  The next closest day program is 30 miles each way.  If you can’t provide programs to serve our loved ones, then you need to support us and stop making things more difficult when we can’t find competent, stable help for the most vunerable members of our society

You need to remove the stipulation about “objective documentation" from this new waiver application and allow live in attendants as long as they can meet the state criteria to be an attendant. It is ludicrous that you are making this more difficult for families  when Virginia is cited in the MACPAC brief as allowing family members as caregivers.    After all, it is a national problem as cited in the MACPAC Brief.


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