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
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3/29/21  10:25 am
Commenter: Kim Jarrett


Support Intensity Scale

200.2.a. 4 years between SIS assessments for ages 22 and over.

COMMENT:  My agency feels, and I agree as a direct support professional, that this distance of time between assessments is detrimental to assuring proper care of the Person who needs the supports.  Currently, requests for re-evaluation are limited and difficult to obtain approval, even when there have been changes to medical or behavioral needs.  

I request that the time frame remain 3 years.  Should the 4 year span remain, the process for reassessment due to changes be made easier and allowances be made for appeal of results when the team does not feel the level reflects need. 

200.B.2. Notations of exceptional medical/behavioral needs will be investigated and may or may not lead to obtaining the exceptional level of services.

COMMENT:  My agency, and I as a direct support professional, express concern about the lack of transparency in the scoring of SIS assessments and how the levels are determined.  In all other assessments and evaluations, scores are shared with the person being assessed along with a determination summary.  Since adopting SIS scoring for rate setting, scoring and interpretation has changed multiple times without transparency.  

We requests the following:
- scoring and determination criteria be posted,

- justification of any reduction in level or tier be sent to the individual,

- and an avenue for appeal be provided to the individual who wishes to appeal the determination, as is the right of all service recipients related to their diagnosis and treatment assessing and planning. 

370.7. Environmental Modification 

COMMENT:  Environmental Modification Services be allowed for sponsored residential services and group homes in cases in which a person has been living in the home for a lengthy period of time without the need for such modifications and has had a significant change in medical status or mobility/accessibility.  It would be a hardship for the individual to be moved to another home that has the needed access, leaving their in place support structure.  For many people who have lived in a location for years, they view that as their home, and rightly so.  They should not be forced to move because the state refuses to support the person in their home.



530.C.1. Residential service limit to 344 days per ISP

COMMENT:  As a provider, I request a re-evaluation of the number of allowable days of billing per year, as 21 days is an excessive number of non-service days for the great majority of people in sponsored residential services who do not have family members to visit or have other avenues of support for this amount of time.  As a care provider, I must continue to provide 24-hour services during this time as well as pay for additional DSPs.  There is literally nowhere else I could work that would expect someone to work for 504 hours a year for $0 in pay.
Kim Jarrett, Family Sharing inc . Provider 13 years 

CommentID: 97459