The Arc of Virginia appreciates the opportunity to review and comment on the Draft EPSDT Private Duty Nursing Services Provider Manual.  The Arc of Virginia is an advocacy organization representing people of all ages with developmental disabilities and their families.

Families of children/young adults who use PDN are often faced with service authorization issues that put their children at risk and poses undue pressure on families.  Some have had services reduced.  Many have complex developmental and medical conditions.  Due to their conditions it is often impossible to predict when the need for discreet nursing interventions will occur.  In addition to nursing interventions they need continuous monitoring and assessment so that when a discreet nursing service is necessary the intervention takes place.   

The Arc of Virginia strongly recommends that the Dept. of Medical Assistance Services include language in the PDN Manual that explicitly states that ongoing monitoring and assessment are activities of private duty nursing. 

Thank you for your consideration of this comment.  

Sincerely,
Lucy Cantrell
The Arc of Virginia