The Arc of Northern Virginia wholeheartedly supports comments submitted by The Arc of Virginia in reference to the proposed Family and Individual Supports Waiver renewal.  Given our extensive information and referral work, and our work as DD Waiver Support Coordinators, there are issues that are of particularly great concern that we would like to address here:

• Ensuring roll out of telehealth and virtual service delivery options that protect privacy.
• Collecting data to assess satisfaction with Waiver services from Waiver users.
• Ensure personal care is an option for individuals utilizing the Individual Supported Employment service, who may require extensive hands on support due to the nature of their disability.  As proposed by The Arc of Virginia, this could be done by Supported Employment providers.
• Allowance of consumer direction for nursing delegation in circumstances where this is the most appropriate option for the Waiver user.
• Clarify regulations to ensure respite is available to people with a paid and unpaid caregiver in the home, the unpaid caregiver is still eligible for respite.
• Allowing legal guardians to provide respite.
• Broaden and clarify the definition of Assistive Technology to ensure fullest access to individuals who may benefit, as under the CMS definition.
• Remove requirements that someone prove they cannot otherwise access or afford transportation in order to obtain Waiver transportation funding, in keeping with all other Waiver services that do not have this requirement.  Allow further service flexibility by allowing vendors and fare-based option, the most viable transportation for many individuals.
• Allow environmental modifications to be made up to 180 days in advance of a planned transition from an institutional setting to ensure people can move to safe, accessible community-based care.
• Remove the requirement that Supported Living be offered in a setting operated by a licensed service provider, which limits utilization for one of the few residential options available to FIS users, further forcing them toward group homes and pursuit of a CL Waiver. 
• Ensure that parents can be paid caregivers to minors using Waivers in either Consumer or Agency directed care, as intended by the tremendous advocacy that brought about this flexibility.
• End the ability of a single Community Services Board to be both Support Coordinator and service provider to an individual Waiver user, a long allowed concerning conflict of interest.

Thank you for your time on this application.  We, like you, are totally dedicated to ensuring that people with developmental disabilities can live full, meaningful lives in their communities.  The proposed adjustments in regulations get us closer to that shared goal.  Without these flexibilities, we further push people with disabilities toward crisis, large group homes or ICFs, and other settings that initially seem easier and less burdensome, and a great cost to their rights, individuality, and to state funds.