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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3/30/21  2:34 pm
Commenter: Rappahannock Area CSB

Comments on Regulations


Please provide clarification regarding Section E, subsection 3.

Can a support coordinator have family receiving services at the agency where the SC works, assuming that the support coordinator is not providing support coordination to their own family member or does having a family member served at that agency prevent the agency from hiring that family member as a support coordinator?



Please provided clarification in Section H. as to whom is responsible for the documentation of annual contact with the individuals on the DD waiver waiting list?  Does DBHDS contact to obtain the choice of home and community based services meet this requirement?



Section A, B, and C

These time lines are not reasonable to meet, considering the number of waivers that are distributed at one time.    There is no allowance for the number of staff who are working with caseloads at or above capacity that will now have 30 days to contact individuals to inform them of their waiver slot, meet with them that month and start their plan and begin the search for services.   There needs to be allowances for boards who don’t have staff to do this.  Perhaps splitting how many slots are provided at one time to the boards, not all in one allotment would assist.   The lower rate or reimbursement for DD case management, makes it difficult to hire staff prior to distribution of slots to allow for time for the SC to be trained and ready to provide services –before the slots are distributed.



Please provided clarification regarding Section C. as to how will criteria for assigning slots be met (notification, meeting etc.) be met if the individual is out of the state for three months and receive a slot?

Please provided clarification regarding Section G, subsection 5  when a slot is vacated in one of the DD Waiver due to the death, the slot shall be assigned to the next individual in that CSB’s chronological Queue.      Does this mean that anytime an individual passes away their slot goes to the reserve slot waiting list for that CSB or is it just those that received their current waiver through the reserve slot process? 



Section 2, subsection e

If the EOR is acting as the service facilitator – who monitors to ensure that they meet all the requirements of a CD service facilitator?

Who writes the service plans?

Who inputs the plans and service authorizations into WAMS if the EOR is the service facilitator?



Section 2

For involuntary disenrollment of consumer directed services – how would the support coordinator have the information about timesheets that would indicate a serious discrepancy?  What is considered a serious discrepancy? 

Section 3 subsection a

What is the essential training that needs to be provided to the EOR to improve the problem condition?


Section 2, subsection c and e

Who is responsible for completing “another developmental appropriate standardized living skills assessment approved by DBHDS” for those who did not receive a SIS assessment?

How are these assessments funded?


CommentID: 97553