I am writing in opposition to the changes being proposed to the Consumer Direct Care program. I am the father of a non-mobile, non-verbal, blind 9 year old boy who requires 24/7 care. The legislation being proposed will negatively impact my family and all families  of children with disabilities .

Page 175  of the Application for 1915(c) HCBS Waiver: Draft VA.006.05.-- - Jul 01, 2023 contains the following statements:

1. "There must be objective written documentation presented at the time of service authorization that demonstrates that there are no other alternatives to the legally responsible individual providing the care and that there are no other viable service/provider alternatives."
2. "Limits are placed on the legally responsible individual's provision of paid care. The legally responsible individual must be employed by a personal care agency, and thus meet all of the same requirements as other personal care aides"

What is objective, written documentation? This is a poorly worded paragraph that makes it more difficult for parents to navigate the DMAS system.

I am fail to see the value provided by forcing the parents to be employed through a provider agency. The overhead charged by a provider agency is money that could be used to provider services for our children. If the concern is to ensure parents are capable of caring for their special needs children, the state should list out the requirements of personal attendants and provide a means for parents to demonstrate they meet those requirements. In its current form,  these changes only add to the bureaucracy and take funds from the most vulnerable of us.

The current program that allows parents to be care takers has been working extremely well and should not be changed.

Thank you,

Concerned Parent