Fairfax- Falls Church CSB agrees and supports all other comments to the date additionally to the below:

1. 12VAC-30-122-80

1. The support coordinator shall notify the individual and family/caregiver of slot availability and available services within the offered waiver within 7 calendar days of the waiver slot assignment date.

The proposed timeline of 7 calendar days as defined in A does not provide CSBs adequate time for the administrative activities that must occur for individual/caregiver notification.  Once slots are assigned CSBs, must go in and review the information and manually fix errors.  Additionally, the slots are often assigned in large groups, with between 40-150 slots at one time.  After the CSB is notified the slot has been assigned and reviewed the list for errors, a support coordinator is assigned to initially begin working with the individual/caregiver.  Then a packet of information is developed to share with the individual/caregiver to ensure appropriate information is provided.  This process takes time and 7 days does not sufficiently give time for the CSBs to complete the tasks. 

Recommend :

? requesting reconsideration of the timeline components for slot assignment notification:  

? at least 15 business days are allotted for individual/caregiver notification after the waiver slot is assigned.  

 ?A process by which CSBs can request more time for notification if needed. 

2. The individual/caregiver will confirm acceptance or declination of the slot within 15 calendar days of notification of slot availability.

Individuals/caregivers often require more than 15 days to accept/deny.  Individuals/caregivers have questions and concerns they want addressed as they make the decision.  The Priority 1 criteria states that individuals/caregivers agree to accept the waiver services within 30 days.

Recommend:

?  reconsideration of the timeline components for slot acceptance.

?individual/caregiver be provided 30 calendar days to confirm acceptance or declination of the slot once notified of availability. 

 ?requesting to add  information on how the Support Coordinator/CSB are to proceed if the individual/caregiver has not made a decision within the specified time period.  What are the responsibilities of the CSB/Support Coordinator and what appeal information needs to be provided to individual/caregiver?

2. 12VAC30-122-20 Definitions

“Progress notes” iii is signed and dated on the day described supports were provided.

The adjusted regulatory language requires that the provider complete all documentation on the same day of service which places an additional administrative burden on the staff, potentially limiting the number of services provided each day, reducing flexibility with services to adjust to the individual need. Recommend:

?Allow at least 24 hours to input the documentation of the service provision.

3. 12VAC-122-390 Group Home Residential Services in section D. Provider qualifications and requirements – number 1 states that “Provider shall meet the following requirements and references reg 12VAC30-122-110 through 140”.   In section D. number 4. Provider shall ensure that staff providing the group home residential services meet provider training and competency requirements specified in 12VAC30-122-180.

Recommend:  

?Include links that will direct to the mentioned regulations.

4. 12VAC30-50-440; 12VAC30-122-190  and thru the content of the Manual

Recommend:

?   Define  90 days i.e., calendar or business days.

5. 12VAC30-122-30

The content is referring to the Elderly or Disabled with Consumer Direction and the Technology Assisted waiver

Recommend:

?  Update language- both Waivers are not currently available.

6. 12VAC30-122-190 C 1

Recommend:

? Define “quarterly” and include 30 days grace period for its completion by the Support Coordinator.

7. 12VAC30-122-190 C 2 a

Recommend:

? clarify “Risk Assessment” and change the wording to the Risk Awareness Tool as currently the Risk Assessment is only completed with SIS completion and not during the annual person- center plan review.