I agree with the posts addressing the need to change the way the SIS is used in Virginia, how the levels are assigned and the reliance on “a day” as the sole reimbursement unit in group home and sponsored placement settings. In our small agency, at least one Individual has been negatively impacted by each of these issues. I also agree with the changes that were recommended by John Malone and others from other CSBs.

In response to Carla Groff’s suggestion for the criteria for substitution of provider staffing to be amended to “registered nurse” VS “experience” for the education requirement: Though some Individuals served in both group home and sponsored-placement residential homes now do require support for complex medical needs, the majority do not. I agree that in situations where an Individual is in need of daily supervision to address the complex health concerns she identified, the agency that has committed to their support should be required to be staffed with licensed medical professionals. I also question her inclusion of colonoscopies as a “complex medical need”. The QDDP functional equivalent has earned, with years of demonstrated knowledge, skills and abilities, an essential role for the majority who do not present with these needs.