At The Arc of Loudoun (Larc) we are disability advocates who work with persons who have many different types of disabilities. We provide waiver and other information to them, and, therefore, we appreciate the complexity of assessment, eligibility, services available, and the unique populations that each waiver serves. Larc supports the definition change to “Intellectual Disability” and the inclusion of person-centered language proposed. We ask that any clustering of terminology and language clarification and consistency proposed will facilitate understanding, yet not minimize individual choice or unique characteristics and needs of people with different types of disabilities who receive waiver services.

There are some areas where we have specific concerns:

1. Requirements for Service Facilitators to be a nurse and/or have a certain type of degree:  With the current shortage of nurses, we have concerns about a nurse requirement. It is difficult for individuals receiving waiver services here in Northern Virginia to obtain the number of skilled nursing service hours that they need.  Also, there are individuals who may be more than qualified with experience to do service facilitation who have a different type of degree.kz

2. Nurse delegation for certain types of services e.g. G-Tube feedings should allow for training of non-LPN or RN staff (including consumer-directed providers) with oversight so that waiver participants with these types of needs have choice and community living maximized;

3. Because Loudoun County borders Maryland and West Virginia, more flexibility and outreach to out-of-state providers by DMAS would be helpful;

4. DD Waiver participants should be able to continue Sponsored Residential types of placements with sponsoring individuals and families. These living situations are NOT group homes and they provide additional supports to individuals with developmental disabilities who are not able to afford an apartment with only SSI income or just need to be in a more supported setting in the community.

5. Individuals who receive a funded waiver slot should be given additional time to find providers before waiver termination notices are sent. In Northern Virginia and other areas, there are few Medicaid providers and it may take time for individuals and families to advertise and find consumer-directed service providers.

Thank you for this opportunity to comment.