RE: CCC CD EOR Manual, July 2019 DRAFT:

Pg 4: “CD services are available in the following VA Medicaid waivers and benefits:

CCC Plus waiver

CL Waiver

FIS waiver

EPSDT Benefit

Are recipient manuals available for each of the above waivers and benefits?

Pg 4: Terms to Know (Services Facilitator)

1. I would like to see more specifics on what the SF are and are not permitted to discuss and the frequency that they may visit. We have had 2 different Service Facilitating Agencies in the past 10 years that my daughter as been on a Waiver. The first agency visited once every 60 days, and stayed in my home for about 10 minutes, asking questions specifically about my attendants, timesheets, etc.

The second agency we worked with currently visits once every month and asks numerous questions, varying from each and every one of my daughter’s medical appointments, to her behavior, changes in my health, my daughter’s sleep patterns, her socialization, her IEP at school, my work hours, my husband’s work hours, and our involvement in the community. These are very personal questions and I find them intrusive. The current SF visits every month and stays for upwards of 30 minutes. I am not sure whether these questions they ask are within their bounds or not but if there were a CCC Plus Waiver Recipient Manual, I would know for sure what is permissible and could better advocate for my daughter and my family’s privacy.

If the SF job is strictly to assist with hiring and firing attendants, then if a recipient has a stable attendant without any issues, then there is no need for such frequent visits with detailed/intrusive questions. And if the SF job is to facilitate all aspects of the CCC Plus Waiver, then the definition of Services Facilitator on page 4 needs to be revisited, and the SF agencies need to be properly trained.

Pg 4: Terms to Know:

Need to add and define EVV

Pg 5: Benefits of consumer-direction…

Reading that list sounds so heavenly however, the negatives that we have faced for the past 12 months seem to overshadow the supposed benefits.

I’d argue that rather than the proposed draft “increased flexibility,” is grossly incorrect as working relations with CDCN after they won the bid over PPL, combined with the mass confusion related to EVV and CellTrak, there is INCREASED FRUSTRATION and INCREASED RIGIDITY.

I would argue that “accommodates individual needs and preferences” in the proposed draft should rather read, “caters to the bureaucracy rather than the individual needs.”

And on the last bullet point, while I agree that the consumer has the opportunity of choice who provides services, the reality is that finding a new attendant is next to impossible with the hoops they must jump through and adhere to (EVV) for a measly single digit dollar per hour.

Pg 5: Back Up Support Plan:

“Individuals who do not have a backup plan are not eligible for CD services.” This seems backwards to me, I think the government has this wrong.  As an American citizen with honesty, integrity, and justice composing my character, I happen to have a daughter with disability.  Leaning on my support system, I see my primary support system as being my family, friends, and neighbors.  It is the government Waiver that is my back-up plan. It seems completely asinine for the government to require me to have a backup plan, for the backup plan.