Agencies | Governor
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 Ends 3/31/2021
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3/30/21  2:56 pm
Commenter: Holly Rhodenhizer

enCircle Comments on Waiver Regulations
  1. 12VAC30-122-120 Provider requirements
    1. Accept training on Crisis Education and Prevention Plans (CEPPs) by DBHDS, or its contractor, based on individual needs.
      1. Comment: please provide clarification on what this training is, where it can be found and to whom it applies.
  1. 12VAC30-122-200 Supports Intensity Scale® requirements; Virginia Supplemental Questions; levels of support; supports packages
    1. a. [ At least every four years for those individuals who are 22 years of age and older.
      1. Comment: It is very challenging to schedule a SIS when needs change. Pushing this from 3 – 4 years could make that burden even greater. Please reconsider maintaining the 3-year schedule or allowing for more flexibility for scheduling a SIS as needs change.
      2. Comment: SIS Scoring – is it possible to share the scoring mechanism with providers? There is question around the consistency of SIS Scores, more transparency with SIS scoring would allow for more consistency and better understanding of why the individual fits into a particular tier.
  2. 12VAC30-122-390 Group home residential service
    1. A. Service description. Group home residential service shall consist of skill-building, routine supports, general supports, and safety supports that are provided to enable an individual to acquire, retain, or improve skills necessary to successfully live in the community. This service shall be provided to individuals who are living in (i) a group home or (ii) the home of an adult foster care provider. Group home residential service shall be a tiered service for reimbursement purposes (as described in 12VAC30-122-210) based on the individual's assigned level and tier and licensed bed capacity of the home. [ The number of licensed beds in a setting reimbursed for group home residential services shall not exceed six. Group home settings larger than six licensed beds that became DD Waiver providers prior to March 31, 2021, may continue to operate and receive Medicaid reimbursement. If a group home larger than six licensed beds changes ownership, the group home will be considered a new setting and the licensed bed capacity limit of six beds shall apply for Medicaid reimbursement purposes. ] Group home residential service shall be provided to the individual continuously up to 24 hours per day performed by paid staff that shall be physically present. This service may be provided either individually or simultaneously to more than one individual living in that home, depending on the required support. Group home residential service shall be covered in the CL waiver.
      1. Comment: Please reconsider allowing a home that is acquired by another agency to remain at greater than 6 beds at least for a period to support the transition. 
  3. 12VAC30-122-550 Therapeutic consultation service
    1. i. Consulting related to person centered therapeutic outcomes, in person [ or, ] over the phone [ , or via video feed consistent with in accordance with the requirements of the Health Insurance Portability and Accountability Act (HIPAA) ].
      1. Comment: Thank you for this addition! This will greatly support a more efficient operation.
    2. 1. The unit of service shall be one hour.
      1. Comment: Please consider moving billable increments to 15 minutes. Some activities such as developing data collection systems or talking someone through an episode may take less than an hour and that may be all the consultant does in a day or week. Depending on how often the consultant works on the case it may take a while to build to that hour. Therapeutic Consultation runs similarly to Skilled Nursing which allows for 15-minute increments.


CommentID: 97556