Virginia Regulatory Town Hall
Department of Medical Assistance Services
Board of Medical Assistance Services
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6/29/21  11:45 am
Commenter: Jennifer G Fidura

Allocation of that Portion of FMAP Relative to the DD Waivers

FMAP as a “bridge” to the “rates rebase” which will, at the earliest, be available July 2022 (six months after the next minimum wage increase)

This provision as part of ARPA, on its face, seems very straight forward.  And while there may be a variety proposals for the funds, VNPP is strongly recommending the following:

  • Pay providers the increased “rate” quarterly beginning on August 1st based on claims billed and paid for any of the eligible services for the period of April 1 through June 30.  Repeat that process for subsequent quarters of July 1 – September 30, October 1 – December 31 and January 1 (2022) – March 31.
  • Require documentation of the appropriate use to be confirmed in a subsequent QMR review; utilize the guidance to be provided by CMS as the options for appropriate use.


    This methodology recognizes several realities:

  • Every provider has different needs – for example, many outside of Northern Virginia are facing a significant challenge to meet the pay increases which will be necessary to remain competitive in the job market after the minimum wage increases in May 2021. 
  • To date all of the COVID relief funding, both State and Federal, has required a complex application process requiring significant effort with strict limitation on options and funds have arrived (if at all) months later. 
  • This methodology is also relatively simple to implement and will require less administrative effort on the part of DMAS staff.

While the CSBs do hold a unique position of both statewide “coverage” and direct accountability, the private sector provides the vast majority of the services in the community in both the behavioral health and developmental disability arenas.  In very simple terms, meeting the needs already identified and those exacerbated by the COVID19 pandemic will be addressed only by building (and in some cases – maintaining) capacity

Building and/or Maintaining the Workforce

80-85% of the cost for any provider is for personnel (payroll, benefits, taxes, etc) and currently there are multiple factors which are driving that cost up in an unsustainable way:

  • A critical shortage in the workforce which in impacting many industries from hospitality to education, but is most certainly impacting the human service/health care industry.
  • Extraordinary competition for employees with industries that have much more flexibility in how they structure their budgets because they have more options for how they fund their businesses.
  • Overwhelming regulatory control which sets standards that are not only administratively burdensome, but are also unnecessarily restrictive of who can be hired (barrier crimes) and who can perform the assigned tasks (mandatory training, ongoing assessments which, if staff lacks “proficiency” in a single skill, threatens the provider’s ability to bill for services , etc.
  • And, most critically, the impact of the long overdue increases in the minimum wage which are not funded in the Medicaid rates structure. 


    The workforce, at all levels including professional staff, is key to building and/or maintaining the capacity of the system.  Lacking that, the next steps will not come to fruition and Virginia’s most critical needs – reducing the pressure on the state hospital system and reducing the waiting list for DD Waiver Services – will not/can not be addressed.

This funding will be a "bridge" to the rebase of the rates which may not be possible until July 2022.

CommentID: 99288