12VAC30-122-530 Sponsored Residential Service C. Service Units and Limits
6. Room and board shall not be components of this service.
While we all recognize that this is meant to indicate Medicaid does not pay for Room and Board, room and board are billed to individuals receiving this service just as they are in Group Homes. What brings this to attention is that this statement is missing from this section under Group Homes. Please indicate somewhere in the Manual that this is allowable practice for Sponsored Residential or years down the road someone in a position of power without institutional knowledge could interpret this to mean it is not allowable and attempt to enforce it as such.

12VAC30-122-390 - Group home – 6 bed max on group homes.
Wall Residences agrees that 6 beds or fewer is the preference for community-based services. However there needs to be some allowance worked into the Manual for this to increase back to 8 (as recognized in Virginia Code) in emergency situations.

12VAC30-122-120 - Provider Requirements

A.5. - ADD “as appropriate”. Training on Crisis Education and Prevention Plans is not applicable to all waiver services. Also, clarity is needed as to whether this is for licensed providers only “as appropriate” or for all providers “as appropriate.”
A.12.c. (4) e. - ADD “electronic signature as acceptable for providers using Electronic Health Records (EHR) programs”.

12VAC30-122-200 - Supports Intensity Scale Requirements, Virginia Supplemental Questions; Levels of Support;
ADD - Appeal process for SIS score. Because SIS assessments are only made every 2, 3 or 4 years depending upon the age of the individual, individuals and their families must be able to appeal the results and present additional or alternative evidence. SIS scores and results are subjective according to the administering agency selected by DBHDS. There must also be flexibility to request a new SIS assessment any time between 2,3, or 4 year requirements when circumstances warrant because of changes in an individual’s needs - especially behavioral or medical support needs.

We need to work on this as a State in the Manual.. In our early meetings about this implementation we discussed the “team” being able to request the reassessment and it would be completed if the team recommended it. This has transitioned into a few individuals making the decision about whether or not a reassessment is done based on the request from the individual/guardian. This process of reassessment needs to be more open with the move to 4 years. We do not need to control the number of assessments being completed as we did early on due to back-logs of original assessments that needed completion.

12VAC30-122-320 - Community Engagement
B. 2. c. Routine and Safety Supports must not be limited to transportation only. These supports may be necessary for and apply to other allowable activities.

12VAC30-122-410 In-Home Support Services B.4. - REVERSE and REINSTATE Stricken Language
EXPLANATION: In-Home Support Services needs the flexibility of episodic supports for all the reasons stated in the stricken language. Without the inclusion and flexibility of episodic supports, the individual will have no support if these events occur.

12VAC30-122-560 - Therapeutic Consultation Services
RECOMMEND that Therapeutic Consultation Services be provided to individuals on the Building Independence Waiver to further create and maintain independence and inclusion for individuals living and working in the community. increase their inclusion in the community and work environments.

The unit of service shall be one hour. Comment: change to 15 minute units for accuracy and quality assurance. ABA Services are provided in 15 minute increments under the MCOs.

Therapeutic consultation shall not be billed solely for purposes of monitoring the individual. Comment: Please define “monitoring.” We were recently pended and engaged in an extensive back-and-forth discussion with Lead PA Consultant due to different interpretations of “monitoring.” Behavior Analysis requires extensive data collection throughout the development and implementation of the Behavior Support Plan. Once a BSP is developed, it should be considered fluid, as changes are continually made based on direct data analysis. Data collected after the development of the plan should not be considered monitoring, until the individual has reached discharge criteria.

Travel time [ , and ] written preparation [ , and telephone communication ] shall be considered as in-kind expenses within therapeutic consultation service and shall not be reimbursed as separate items.
Comment: Please define written preparation as an in-kind expense. What documentation does this include and not include?

General Comment under Therapeutic Consultation: Licensed Professional Counselors are Master’s level licensed professionals. In general this is a minimum of 8 years of a combination of higher education and supervised post Master’s training. For many this takes 10 years or longer to obtain, much longer than required for a PBSF and longer than many BCBAs. Move these professionals to the same level as BCBAs for reimbursement of Therapeutic Consultation.

We still need to move Music Therapy (provided by actual trained and Certified Music Therapists) into Waiver Services as an option. We provided this for decades to individuals when they resided in training centers and our state mental health facilities but they are unable to receive the service now in the community. This would fit very well here in Therapeutic Consultation and open up a very valuable service option.