Concerned that DD Support Coordinator and Supervisor are positions of critical importance and it is difficult to recruit and retain qualified staff. Standards must be high but not prohibitive.
Under section 12VAC30-50-490 Support coordination/case management for individuals with developmental disabilities, recommend
Modify the supervisor requirement from two years of experience to one year of experience to allow for a broader qualified applicant pool
DD Support Coordination:
Concerned that definition of DD Support Coordination is too narrow to allow for providers to serve everyone in need of this support.
Definition of services currently states that services will be provided for Medicaid-eligible individuals with developmental disability or related conditions who are on the DD waivers waiting list or enrolled in one of the HCBS services.
Recommend allowing services to be provided for Medicaid-eligible individuals with DD or related conditions even if they are not currently on the wait list or enrolled in services. Often these individuals need and can benefit from support coordination and struggle to enroll in services without assistance.
Target Group Definition:
Concerned that the definition of the Target Group is not clear.
It would be very helpful to have a definition of ID and DD regarding eligibility for services.
Request clarification regarding what documents are acceptable for a DD diagnosis as approved by DMAS. For example, is an encounter note from a physician that lists a diagnosis sufficient?
Concerned that the regulations suggest a VIDES is required annually for those on the waitlist; this would be labor intensive and time consuming for these hundreds of individuals.
Under section12VAC30-122-50 Criteria for all individuals seeking Developmental Disability Waivers services, the following is stated:Individuals qualifying for the DD Waivers services shall meet the level-of-care provided in an ICF/IID [ as set forth in the VIDES ] and shall demonstrate this need at least annually consistent with 42 CFR 441.302. [ This is demonstrated by having significant functional limitations in major life activities, as documented on their Virginia Individual Developmental Disabilities Eligibility Survey (VIDES) forms
Recommend the VIDES is not be required to be completed annually for those on the waitlist.
If VIDES are required annually, funding will be need to allow for the significant increase in work and staffing to accomplish the task, suggest utilizing a shorter assessment.
Waiver Population – recommend to update terminology