Virginia Regulatory Town Hall
Department of Medical Assistance Services
Board of Medical Assistance Services
Waivered Services [12 VAC 30 ‑ 120]
Action Three Waivers (ID, DD, DS) Redesign
Stage Final
Comment Period Ended on 3/31/2021
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3/28/21  4:47 pm
Commenter: Peaceable Life Therapeutic Services, Inc.

Therapeutic Consultation 12VAC30-122-550

550.B.2.i - Telehealth and phone options for visits to be permanent.

COMMENT:  YAY!! Thank you for this!  Telehealth has allowed us to be able to connect with those we are supporting much more frequently and effectively! Love this change.

550.C.5.a,b,and c - Initial SARs will be approved for only 180 days after which point a new SAR will need to be submitted with accompanying documentation including baseline Data.  Annual renewals will need to have an annual summary of quarterly data.

COMMENT:  Though we understand that the purpose is to assure that plans are meeting the expectation of content, resubmission of a plan for support at 180 will cause delays in continuation of services.  In multiple areas of Virginia, we are unable to receive approval for a Plan for Support for a plan renewal in less than 60 days.  If it is pended, it will be delayed longer.  In addition, initial PFSs will often take 60 to 90 days for authorization.  In these cases, we cannot start services until they are approved which is 3 months into the requested plan time and we will have only 3 months of data or information to submit.  Followed by further delays in Plan renewal authorization at the 180 day end-date.   

We request the removal of the 180 day resubmission requirement and request that the accompanying documentation be required for annual renewal.  

550.E.e.(1)and(2) - quarterlies must include graphs and charts 

COMMENT:  We request that this be modified to  read that quarterlies must include summary of progress which may include charts and graphs.

PBSFs rely on team participation for data collection. Surveys within the PBSF community rate data collection as the #1 barrier to plan completion and site that data is often not completed at all or is completed incorrectly. PBSFs often have to resort to record reviews of alternative documentation that the residential provider uses internally, direct observation during visits/telehealth, and anecdotal reports to measure progress and response to interventions.  Broadening the scope of this requirement to include a summary of progress will allow for presentation of data as it is available and will afford the PBSF opportunity to document on the quarterly the barriers with obtaining proper data so the team can measure progress with team participation.  In addition, it will avoid delay of services to the individual due to pending of authorization by PA when the charts and graphs do not look a particular way.

CommentID: 97449