We would like to reiterate the comments made by Andrea King with Valley Associates for Independent Living. On behalf of Virginia Association of Centers for Independent Living we support Andrea King's comments:

On page 5 under "Who is Eligible for Consumer-Directed Services?" - the first set of bulleted items are already listed on page one under Introduction.

On page 6, it lists that, "if the EOR has questions, they should discuss them with the individual's MCO care coordinator or call the number on the back of the CCC Plus program identification card."  Why not state that the individual should contact their service facilitator, as individual's often do not even know who their care coordinator is or have easy access to them.  SFs tend to be more available to individuals and also are more familiar with the information being shared in the EOR manual / hiring processes in general.

On page 6, VA Premier Elite Plus is listed as changing to CDCN on 9/26/19.  Since has already changed, should change in manual.

On page 6 under "Which Waiver Services can be Consumer-Directed?" it states that companion services are different for CL and FIS waivers.  I would question as to what is different in these waivers for this service.  That statement does not make sense.

Page 6, same section as above, there is a starred statement at the bottom regarding skilled Respite services that is already stated in the paragraph right above this one.  

Page 7, second sentence in states that the "waiver individual must be able to supervise and direct their CD attendant in carrying out the tasks."  It has been my experience that, in order to meet this exclusion for service approval, the individual actually has to be their own EOR, not just be able to direct the CD attendant in carrying out the tasks.

Page 8 lists the role of the Services Facilitator and is a good representation.  With that being said, why refer the individual to their care coordinator in the beginning of the manual for questions when the SF is more available / able to answer hiring questions.

Page 9 states that the SF is responsible for conducting the annual LOC process.  This is only true for DMAS SF individuals.  

Page 9 also states that Community Services Board support coordinators cannot be SF.  This is not true and is allowable in the FIS waiver.  

Page 9 should include links to all FE/A programs, not just PPL.

Page 11 still refers to timesheets; however, these will no longer be accepted after 12/31/19; therefore, this information should be eliminated from the manual.  Information regarding EVV should be included instead.  

Page 13, The service plan - the final bullet under that section does not make any sense.

Page 20, under Attendant Job Descriptions, the last sentence in this section talks about an attendant application and, therefore, doesn't seem to fit with this section.

Page 21, Interviewing Applicants - the first 2 paragraphs under this section say essentially the same thing.

Page 34 - Incorrect address listed for CDCN.  Moreover, this page states that CCC plans with the exception of Magellan remain with PPL.  This is not true, as VA Premier now uses CDCN; therefore, that should be included.

Throughout this document, timesheets continue to be referred to.  Since it has been made abundantly clear that this is no longer an option after 12/31/19, information on EVV should be included instead and ALL references to timesheets should be eliminated.