12VAC 30 - 122-390 C1:

The proposed regulations establish “a day” as the unit of service for reimbursement for group home residential support. This is harmful to individuals and residential providers. Reimbursement rates are based on two factors; SIS score and size of home with the SIS score carrying the most weight. The SIS measures intensity, duration and frequency of supports. The latter two variables are significantly effected when an individual stays home (does not attend a day placement/supported employment) for any reason. Along with an aging population that is unable or uninterested in attending available day support options, many of the individuals supported suffer acute and chronic health conditions which increase the intensity, duration and frequency of supports provided (scheduling/coordinating and carrying out medical appointments, eg.) while reducing their attendance to day programs.

Periodic Supports for residential supports should be reinstitued for this very reason.