Region 2 Developmental Services (DS) Directors appreciate the opportunity to comment on the Waiver regulations and recognize the tremendous amount of work DMAS has invested in the updates.  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: 

1. The support coordinator shall notify the individual and family/caregiver of slot availability and available services within the offered waiver within 7 calendar days of the waiver slot assignment date.
2. The individual/caregiver will confirm acceptance or declination of the slot within 15 calendar days of notification of slot availability.

Some of the challenges of implementation of the regulations as stated for each of these components are outlined below.

A.  The support coordinator shall notify the individual and family/caregiver of slot availability and available services within the offered waiver within 7 calendar days of the waiver slot assignment date.

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. 

B.  The individual/caregiver will confirm acceptance or declination of the slot within 15 calendar days of notification of slot availability.

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?

Thank you for your consideration of our recommendations and requests outlined above.  We are happy to provide additional information and can be reached by contacting, Lisa Snider, our Region 2 DS council chair, at lisa.snider@loudoun.gov.