1020 F.2.b Recommendation:  Authorize environmental modifications by the plan year not the calendar year. 

The proposed regulations have services received on three different cycles.  There is the plan year for most services, the calendar year for assistive technology and environmental modifications and the state fiscal year for respite.  Having so many different year definitions is confusing and hard to manage for the recipients, family and service providers.  Assistive technology and environmental modifications requests are currently based on plan year dates and occur throughout the year.  If assistive technology and environmental modifications are put on a calendar year, case managers and providers  will be overwhelmed at the end of the year with requests.  To avoid this and to reduce confusion for all involved, services authorizations should all be by plan year. 

1020 K.4 Recommendation:  Maintain the current policy that allows people to use respite hours throughout year when needed is critical.  Remove the proposed language that would only allow individuals to use 240 hours of respite every six months.

The current policy is person-centered and responsive to the needs of individuals and families, allowing them flexibility to plan and be prepared for emergencies depending on individual circumstances.  Circumstances such as school schedules and employment demands require that respite hours be available on a calendar year so that they can be available and used to care for an individual when it is most needed.   When individuals with the waiver experience illness or decline, respite is the support that often maintains the individual and family through the illness.  Families who are caregivers have to deal with their own illnesses or there may be sudden death necessitating immediate respite. These are crisis situations that cannot be scheduled according to a limited amount of respite available every six months.  Without this flexibility it is very likely that there will be more crisis situations resulting in increased costs and hospitalizations.  

From a financial standpoint it would be to the Commonwealth’s advantage to maintain the current policy so that people will bank hours for an emergency rather than using their hours up every six months.  When hours are banked and then not used entirely there is a cost savings to the Commonwealth.  However as proposed, people will be encouraged to use up the hours at the end of six months and there would be less of a cost savings.   

The Arc of Virginia endorses the public comments from the Virginia Medicaid Waiver Network.