I support the comments submitted by the Virginia Ability Alliance.  In particular, I ask that you allow for a spend down  for people with DD waivers  
People with the DD Waivers do not have the option to “spend down” income over the Waiver income cap on medical expenses to demonstrate eligibility for Waiver. The net result is that people with either
high earned or unearned income are ineligible for the DD Waivers, though they are eligible for the CCC Plus Waiver that does have a “spend down” option. As we see the generation of baby boomers retiring and SSDI payments to adult children reaching and exceeding the limits of financial eligibility for Waiver, it would be wise to amend the DD Waiver Regulations to allow a “spend down” option similar to that allowed under the CCC Plus Waiver. Additionally, regulations should protect eligibility for anyone who is put over the monthly income cap as a result of SSDI received from parents. This benefit cannot be refused or reduced, despite the wishes of the person with a disability, yet it can have the effect of making them ineligible for crucial services they cannot afford to fund with their own incomes.