OVERALL COMMENTS:

1. Appreciate the addition to Respite to not require the submission of a quarterly report when respite is not provided to the individual during the quarter.
2. Consistency between DD Waiver Regs/Manual and Licensing Regs regarding submission of Quarterly Report to Support Coordinator for all services.

For Example:  Ch. IV, p.212 - Respite: 

· The content of each review must be discussed with the individual and family member/caregiver, as applicable and submitted to the Support Coordinator within 10 calendar days following the end of each ISP plan quarter. . .

The requirement should be changed to match up with the licensing regulations found below in 12VAC35-105-675.D.3 which states:

For goals and objectives that were not accomplished by the identified target date, the provider and any appropriate treatment team members shall meet to review the reasons for lack of progress and provide the individual an opportunity to make an informed choice of how to proceed. Documentation of the quarterly review shall be added to the individual's record no later than 15 calendar days from the date the review was due to be completed, with the exception of case management services. Case management quarterly reviews shall be added to the individual's record no later than 30 calendar days from the date the review was due.

3. Barrier to AT Access for children under 21.  By putting AT under the 21 year old age group under EPSDT, the criteria is a barrier to access for this group in getting AT items to “increase ability to control environment, support ISP outcomes as identified, and live safely and independently in the least restrictive community setting”. The EPSDT criteria is more restrictive than the Waiver AT criteria for those under 21 versus those over 21 under the Waiver. EPSDT criteria must be for the treatment of the individual’s disability or to improve a physical or mental condition”. We understand that EPSDT has to be the first priority for authorization and payment.  Recommendation: If an individual under 21 that has a waiver slot and does not meet the EPSDT requirements, they should be automatically referred to eligibility standards under the DD waiver.  Those that have a waiver slot should have access to the same standards and services whether they are under 21 or over 21. 

CHAPTER 2

Page 22 - the link takes you to VCU website but says the page is not active and the link as noted below on page 23 goes to the VA Code. Still has incorrect form numbers. For example, the DSP Basic competency and health competency have the same form number.  This has never been updated. 

Previous Comment submitted during last review (Nov 2021). A signed assurance document confirms the receipt of instruction in the required training topics. Assurance documents are specific to DSP/DSP Supervisor role. There are two versions and DSPs and DSP supervisors complete the version that matches their role within the organization. These assurance documents are available online at: https://law.lis.virginia.gov/admincode/title12/agency30/chapter122/section9998/

These forms at this link had incorrect form numbers, etc. A vaACCSES member previously let Jason Perkins and Eric Williams know this back in 2021 and this still has not been fixed.

CHAPTER 4

Page 126:

We understand that this section is included to be consistent with DARS.

Here is our recommendation for edits to improve language:

When the individual has demonstrated a period of stability in employment independent of service intervention the individual supports may move to a follow-along status. Stability in employment is determined by the following criteria:

· Intervention has reached a "plateau" or leveled out;

· Individual demonstrates appropriate work behaviors and social skills on the job;

· Individual can perform expected job duties;

· Individual is satisfied with the job and work environment;

· Supervisor is satisfied with the individual’s job performance;

· Necessary worksite modifications and accommodations are in place;

· Transportation to and from work is reliable; and

· Compensation is at or above minimum wage and not less than wages paid by employer for same work performed by people without disabilities.

Follow-Along is defined as those on-going supports necessary to assist an individual with a developmental disability to sustain maintain competitive work in an integrated setting of their choice. Upon reaching stability and follow along, the support team and the individual should discuss whether:

Page 127:
Here’s our recommendations for edits:

·  Vocational or job-related discovery (we are recommending to take this out as its confusing and is covered in the CE section) or assessment such as a situational assessment – when the individual completes attempts work tasks in one or more competitive employment environments in the community. The purpose of the SA is to assist individual in determining vocational options, direction, goals and training strategies.