Virginia Regulatory Town Hall
Department of Medical Assistance Services
Board of Medical Assistance Services
Waivered Services [12 VAC 30 ‑ 120]
Action Omnibus Waiver Regulatory Changes
Comment Period Ended on 7/9/2008
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6/26/08  11:23 am
Commenter: Alleghany Highlands CSB

Comments on the NOIRA for Omnibus Waiver Services

Our division has extensive experience with the MR, MR Day Support, IFDDS,, and ECDC Waivers, it is obvious that any attempt to streamline all  waivers to eleminate inconsistencies would wreck havoc on the provider community, totally disregard the uniqueness/diversity of each targeted group, and provide no help to families in navigating these waivers.  It would, however, serve to say...."we consolidated as requested". 

Waviers are designed for specifc targeted groups of individuals who have very specific needs (i.e. Aids,MR, DD, Elderly, etc) .  Consequently, by  target specific conditions/groups of individuals, assessment tools unique to these conditions/groups are required.  Language used to describe services are also unique to secific groups.  Because of the uniqueness , monitoring and oversight needs also to be very specific and should be conducted by agencies having experience with specific conditions;  a generic format will not work.

Regardless of the disability field, our task is to look at people as individuals first.  By consolidating all the waivers, we would lose sight of this uniqueness.  VAPPis correct.  An apple is an apple and an orange is an orange.  We get that and so do the people who are the recepients of these waivers.

CommentID: 1634