We respectfully request the 10% FMAP for Medicaid HCBS be used for a rate increase for  Medicaid Agency Directed Personal Care Providers as this waiver is not adequately funded to care for the Commonwealth's most vulnerable population.  Agency Directed Personal Care Providers have already incurred the increased costs associated w/Covid-19 and the loss of revenue and continue to be impacted by the minimum wage increase which took effect May 1, 2021.  Agency Directed Providers are facing an additionally unfunded minimum wage increase January 1, 2022 which will further jeopardize our ability to continue to provide crucial community home based personal care at a tremendous cost savings to the Commonwealth over these same recipients receiving care in a skilled nursing or rehab facility.

In order to continue providing this invaluable home based community service to the Commonwealth's most vulnerable population, we recommend Virginia State policy makers:

1. Pursue a strategy which will maximize reimbursement for Personal Care Providers allowing them to provide personal care to Medicaid recipients in their home, train and hire staff to meet the need in localities.
2. The rate increase should be retro-active to April 1, 2021
3. The directed payments provision of 42 C.F.R. § 438.6 (c) should be invoked to ensure increased funds are indeed distributed to Managed Care and allocated to Personal Care Providers.

Sincerely,

Catherine B. Birley

Executive Director, AmeriCare Plus In-Home Personal Care Agency