|Action||Omnibus Waiver Regulatory Changes|
|Comment Period||Ends 7/9/2008|
Thank you for the opportunity to comment on the intention of the Department of Medical Assistance Services (DMAS) to publish Omnibus Waiver Regulations.
Danville-Pittsylvania Community Services (DPCS) appreciates the intention to streamline regulations; however, it is our belief that while there may be some cause for certain components of the regulations to be consolidated, the Mental Retardation (MR) Waiver and MR Day Support Waiver regulations should remain entirely separate beginning with 12 VAC 30?120-211 through 12 VAC 30-120-249 and 12 VAC 30-120-1500 through 12 VAC 30-120-1550. These two Waivers have many unique and significant features that must be retained. In addition, these Waivers have played a major part in public policy discussions and decisions made by Virginia’s elected officials since the MR Waiver was first developed in the early 1990’s.
The Department of Mental Health, Mental Retardation and Substance Abuse Services (DMHMRSAS) developed the MR Waiver, at the direction of the General Assembly and the Administration, in consultation with Community Services Boards, DMAS, and various advocates. Within DMHMRSAS resided the experience and leadership for services for persons with Intellectual Disabilities. As a result, the MR Waiver was intended to offer services and supports for people with Intellectual Disabilities who were able and chose to live in their communities, and it was based upon the best expertise and knowledge of the needs of individuals with Intellectual Disabilities. The history of the MR Waiver’s development, oversight, and implementation, all of which occurred in the public eye and was the focus of two important legislative subcommittees, is too lengthy to describe in these comments. The results of this history, listed below, constitute the reasons why the MR Waiver and the MR Day Support Waiver should be entirely separate:
Thank you again for this opportunity to offer comments.