Martha Maltais, Region Ten Community Services Board
Omnibus Waiver Regulations
Region Ten Community Services Board appreciates the opportunity to comment on the intention of DMAS to publish Omnibus Waiver Regulations.
At Region Ten, we stand in agreement with many other community services boards in our belief that the 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.
Because these Waivers are one of a kind in so many ways, we believe that moving forward with Omnibus Waiver Regulations is problematic and presents a confusing end result for those governed by these regulations and other stakeholders. The current system allows for greater understanding of these regulations for citizens of the Commonwealth that seek information in a user friendly way. The MR waiver has a long history and nuances that are specific to these waivers. Activities such as the assessment process, preauthorization and the management of waiting lists are unique to the MR waiver. Management of the MR waiver has forged a much neededpartnership between DMAS and DMHRMSAS.
One of the most problematic features of the Omnibus regulations would be that all sections of these Waivers would be opened each time the agency needed to suggest changes to any Waiver. Such a continuous regulatory process would place additional burdens on everyone, including DMAS staff and upon the agencies, consumers, advocates, families, and providers.
Although these waivers are complex, they are manageable in the current format. Omnibus Regulations would create an unintended consequence of confusion and loss of efficiency.
Therefore, Region Ten Community Services Board encourages you to decline moving forward with Omnibus Regulations..