Comment:  Support SIS assessments every 4 years.

There are comments mainly from providers requesting that the frequency of SIS assessments occur every 3 years vs. every 4 years as the proposed regs state.  For many the SIS assessment is not needed to be more frequent.  However it should not be so difficult to obtain a SIS assessment if it is needed.  It is recommended  that waiver beneficiaries have the option to request a SIS assessment every 3 years and those who do not need an assessment after 3 years may wait until 4 years.  

Comment:  Support spend-down being allowed in DD Waivers.

The loss of Medicaid DD Waiver eligibility due to the lack of spend down is unfair and devastating to people impacted.  A person with a DD Waiver should not be penalized because of their own earnings or because of the unearned income they receive as a survivor.  Our adult child (SIS Level 6) will likely lose DD Waiver eligibility when the higher earning parent dies.  This  future benefit loss for our adult child and ourselves who worked multiple jobs and are working way past retirement age to ensure adequate income to cover years of very high medical  and teen and adult care costs that were not covered by private insurance.  Our adult child did not qualify for Medicaid until adulthood and and did not receive a waiver until adulthood.  Our income was/is modest has never come close to those of you who are earning 6 figure incomes reading this comment.  

Thank you for considering these comments.