In the General Assembly budget language, the following is written:

“313.DDDDDD. The Department of Medical Assistance Services, in coordination with the Department of Behavioral Health and Developmental Services, shall submit a request to the Centers for Medicare and Medicaid Services to amend its 1915(c) Home & Community-Based Services (HCBS) waivers to allow telehealth and virtual and/or distance learning as a permanent service option and accommodation for individuals on the Community Living, Family and Individual Services and Building Independence Waivers. The amendment, at a minimum, shall include all services currently authorized for telehealth and virtual options during the COVID-19 pandemic. The departments shall actively work with the established Developmental Disability Waiver Advisory Committee and other appropriate stakeholders in the development of the amendment including service elements and rated defined methodologies. The department shall have the authority to implement these changes prior to the completion of the regulatory process.”

This language was passed as it is written above by the General Assembly.  

It is my understanding that Service Facilitation has been included in the draft amendment from DMAS with only 1 of our 5 services - Management Training (MT).  MT is only formally provided at the request of an EOR and is normally completed during a Routine Review or Reassessment.  From our experience, MT is 99.9% of the time, never a stand-alone service.  

The actuality of the amendment, the way it is written, DMAS has not included Service Facilitation at all in their request to continue to allow telehealth as a delivery method after the PHE has ended.    

The budget language states that “……ALL SERVICES CURRENTLY AUTHORIZED FOR TELEHEALTH AND VIRTUAL OPTIONS ……” should be included in the amendment.    

We submit that all of our services should be included in the amendment and submitted to CMS for their decision. 

Services:        T1028 – 6 Month Reassessment

                        99509 – Routine Assessment

                        S5116 – Management Training

                        H2000 - Initial Comprehensive Visit

                        S5019 – Comprehensive Training

Thank you.