Service Units and service limitations: Block definition is defined as “a period of time from one hour through three hours and 59 “seconds”.
Should be “a period of time from one hour through three hours and 59 seconds minutes.”
Needs to be changed from seconds to minutes throughout section.
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Day Support Service Units and Service Limitations
5. “Service providers shall be reimbursed only for the amount and level of day support services included in the individual’s approved Plan for Supports based on the setting, intensity and duration of the service to be delivered.”
This wording suggests that any preparation such as administering and analyzing the SIS would not be reimbursable.
Wording needed to allow flexibility in Manual language that allows providers to be compensated for SIS analysis and administration.
SIS development as a key component of the Plan for Supports should be an allowable billable service.
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Support the change from Unit to Unit Block.
This supports a clear definition of “rounding” when increments of time are provided. The new definition seems logical and easier to implement in that a Unit Block is ANY time from one hour through 3 hours and 59 minutes. Anything over one hour would equal one Unit Block.
Further definition (and example) is needed in Manual for consistent interpretation across Virginia. Additional training is needed for Community Resource Consultants so that consistent TA can be provided across the state.
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Prevocational Services
I.5. “Prevocational services shall be provided when the individual’s compensation for work performed is less than 50% of minimum wage.”
Should be deleted. Provides disincentive for an individual to be in Prevocational versus Day Support. Day Support does not have this provision.
Many states no longer include this provision in their regulations with approval from CMS.
DELETE 5. Prevocational services shall be provided when the individual’s compensation for work performed is less than 50% of minimum wage. Depending upon the geographic area, a person with significant disabilities may be at a low productivity but compensated at a higher wage even with a low productivity. This higher wage may exceed 50% of the minimum wage based on a higher salary or wage in that area. (i.e. NoVa). We do not want to provide a disincentive to working at a higher wage.
