Agency
Department of Medical Assistance Services
 
Board
Board of Medical Assistance Services
 
Previous Comment     Next Comment     Back to List of Comments
10/1/26  2:03 pm
Commenter: Ebony Feliz, MSN, APRN, FNP-BC

DMAS Policy Review and Request for Updates Regarding Children with Neurodevelopmental Disabilities
 

Virginia has an opportunity to strengthen its continuum of care for children with neurodevelopmental disabilities by ensuring that Medicaid policy recognizes not only whether a service exists, but whether families can realistically access that service.

Children with developmental disabilities should not have to wait until their needs become institutional, medically catastrophic, or otherwise reach a crisis threshold before their families receive meaningful support.
 
Early, accessible, family-centered intervention is an investment in the child’s health, the stability of the family, and the long-term health of the Commonwealth.
 
Authorization is not the same as access. Eligibility is not the same as care.
 
Virginia’s policies should strive to ensure that when a child qualifies for medically necessary support, there is a realistic pathway for that support to be delivered.
 
I respectfully request that DMAS evaluate the following policy areas:
  1. Review EPSDT parent-caregiver restrictions.
    Consider establishing a pathway that permits a parent or legally responsible individual to provide compensated EPSDT personal care when extraordinary disability-related needs exist and reasonable efforts to secure an outside caregiver have been unsuccessful.
  2. Establish a caregiver-unavailability exception.
    When authorized services cannot be staffed within a defined period, families should have an alternative pathway rather than simply going without care.
  3. Improve provider education regarding EPSDT personal care.
    Develop clearer statewide education and guidance so Medicaid personal-care agencies understand EPSDT eligibility, authorization, billing, and service requirements for children.
  4. Develop pediatric-specific caregiver training.
    Create or support training addressing autism, intellectual and developmental disabilities, communication differences, sensory needs, behavioral challenges, safety concerns, and care refusal.
  5. Examine reimbursement and workforce incentives.
    Determine whether current reimbursement structures adequately reflect the complexity of caring for children with significant developmental and behavioral needs.
  6. Review the gap between DD Waiver eligibility and actual waiver enrollment.
    Children waiting for DD Waiver services should have meaningful interim supports appropriate to their functional needs.
  7. Measure access by service delivery—not authorization alone.
    DMAS should evaluate how many authorized EPSDT personal-care hours are actually staffed and delivered. Unfilled authorized hours should be considered an access-to-care problem.
This request is not based on the premise that Virginia has no programs for children with developmental disabilities.

Programs exist. The concern is that the pathways between those programs can leave children and families without usable support.

  1. A child can have documented disabilities.
  2. A child can require assistance with daily living.
  3. A child can qualify for Medicaid.
  4. A service can be medically necessary.
  5. Hours can even be authorized.
  6. But if no caregiver can be found, and the parent who is already providing the care cannot be compensated to provide it, the practical outcome remains the same: The child has no accessible caregiver, and the family remains unsupported.
CommentID: 242077