November 10, 2020
TO: Emily McClellan, Regulatory Manager, Division of Policy and Research, Department of Medical Assistance Services
FROM: Teri Morgan, Executive Director, Virginia Board for People with Disabilities
RE: Public Comment on the High Needs Support Benefit Delivery System Design
The Virginia Board for Disabilities serves as Virginia's Developmental Disabilities (DD) Council. Part of federally-funded network in every state and territory of the United States, Councils work for the benefit of individuals with DD and their families to identify needs of people with disabilities and help develop policies, programs and services that will meet these needs in a manner that respects dignity and independence.
The Board has reviewed DMAS’ policy paper, High Needs Supports: Operational Design and Implementation Planning, detailing the High Needs Supports (HNS) benefit, which will provide housing and employment support services to the Commonwealth’s high-need Medicaid enrollees as part of Virginia’s Section 1115 Medicaid demonstration. As advocates for people with disabilities, the Board supports a HNS program that empowers individuals to fully participate in their communities through stable housing and integrated employment.
Based on our review of the policy paper, we seek additional clarification from DMAS in the areas described below. Answering these questions will help provide clear guidance about the program’s proposed eligibility and implementation.
NETWORK ADEQUACY & COMPLIANCE STANDARDS
ASSESSMENT AND REASSESSMENT
The Board appreciates the opportunity to comment on the HNS program, which will help Virginians secure stable housing and integrated employment. In addition to the comments above, we echo and support the comments of our colleagues at the disability Law Center of Virginia.
Please do not hesitate to contact Clare Huerta, Deputy Director of Policy and Legislative Affairs, at firstname.lastname@example.org if you have additional questions. Thank you for the opportunity to provide input.