Virginia Regulatory Town Hall
Department of Medical Assistance Services
Board of Medical Assistance Services
Waivered Services [12 VAC 30 ‑ 120]
Action Three Waivers (ID, DD, DS) Redesign
Stage Final
Comment Period Ended on 3/31/2021
Previous Comment     Next Comment     Back to List of Comments
3/26/21  4:57 pm
Commenter: Andrea Plumley

From: 12VAC30-122-180?Orientation testing; professional competency requirements; advanced competenc

2. Providers shall ensure that DSPs and DSP supervisors pass or have passed, with a minimum score of 80%, a DMAS-approved objective, standardized test of knowledge, skills, and abilities demonstrating knowledge of the topics referenced in subdivision 1 of this subsection prior to providing direct, reimbursable services. Other qualified staff who have passed the knowledge-based test shall work alongside any DSP or supervisor who has not yet passed the test. 

Comment:  With ID waiver employees have not been allowed to work until they have completed DSPO, passed the test, and have DSPO Assurance.  Is this correct in stating people (including supervisors) can work DD Waiver without these requirements if they are working with someone who has met the criteria.   


3. The director of the provider organization or the director's designee shall complete the competencies checklist (DMAS Form P241a) for each DSP supervisor within 180 days from date of hire with annual updates thereafter, 

Comment – For Supervisors is this 180 days after hire or 180 days after promotion to supervisor? 

  1. Upon discovery of a staff person's inability to demonstrate proficiency, the provider has seven calendar days to begin remediation of the identified skills and document the issue and the actions taken by the agency to confirm proficiency.? This initial seven day process is considered a first episode of one or more identified deficiencies 


  1. If proficiency is not reconfirmed within seven days following discovery of a second episode, occurring within three months of the staff person's inability to demonstrate proficiency, the skills being remediated shall only be performed under direct supervision, observation and guidance of qualified staff who document the provision of these supports in the person's record. 


Comments: This is confusing.  I am reading first episode – 7 days to remediate (what if that does not happen or more time is needed?)   

Second episode within 3 months is also confusing.  3 months from first episode or quarterly after Competency checklist completed? 

CommentID: 97425