|Action||Three Waivers (ID, DD, DS) Redesign|
|Comment Period||Ended on 3/31/2021|
. We are requesting reconsideration of two timeline components for slot assignment notification and acceptance defined in 12VAC-30-122-80. The two components are listed below:
Some of the challenges of implementation of the regulations as stated for each of these components are outlined below.
The proposed timeline of 7 calendar days does not provide CSBs adequate time for the administrative activities that must occur for individual/caregiver notification. Once slots are assigned CSBs, must go in and review the information and manually fix errors. Additionally, the slots are often assigned in large groups, with between 40-150 slots at one time. After the CSB is notified the slot has been assigned and reviewed the list for errors, a support coordinator is assigned to initially begin working with the individual/caregiver. Then a packet of information is developed to share with the individual/caregiver to ensure appropriate information is provided. This process takes time and 7 days does not sufficiently give time for the CSBs to complete the tasks. We would recommend (1) at least 15 business days are allotted for individual/caregiver notification after the waiver slot is assigned. (2) A process by which CSBs can request more time for notification if needed.
In our experience, individuals/caregivers often require more than 15 days to accept/deny. Individuals/caregivers have questions and concerns they want addressed as they make the decision. The Priority 1 criteria states that individuals/caregivers agree to accept the waiver services within 30 days. We recommend individual/caregiver be provided 30 calendar days to confirm acceptance or declination of the slot once notified of availability.
Additionally, we request information on how the Support Coordinator/CSB are to proceed if the individual/caregiver has not made a decision within the specified time period. What are the responsibilities of the CSB/Support Coordinator and what appeal information needs to be provided to individual/caregiver?