The Virginia Association of Community Services Boards strongly believes that DMAS should use the enhanced FMAP funds available as a result of the ARPA to serve as a stop-gap measure until a full rebase of the rates for DD Waiver services is completed and fully funded by the General Assembly.

This approach will:

• Ease the incredible burden providers face as a result of the increase in the minimum wage as Medicaid providers are reimbursed at the Medicaid rate regardless of whether that is enough to cover the cost to deliver the service.
• Help with the recruitment and retention of a workforce to support Waiver service delivery.

This approach should be implemented as follows:

• The state should not place any more restrictive requirements on accessing the funds than what the federal government requires and the state should interpret the CMS guidance on these funds as broadly as possible.
• Providers should receive payments for their portion of the funds, based on claims billed, on a quarterly basis.  For example, on 01 AUG 2021, a payment would be made based on billing for any eligible services over the period of time between 01 APR 2021 and 30 JUN 2021.
• Documentation and accountability for the appropriate use of the funds should be confirmed in conjunction with an existing auditing/review process and cycle.  For example, appropriate use could be determined at an upcoming QMR review for the provider as opposed to requiring a separate process for these funds.

As the state begins to interpret CMS guidance in this area, the VACSB asks that it consider funding for the existing Individual and Family Support Program (IFSP).  The VACSB believes this could fall under the category of enhancing HCBS services, or perhaps, while not strictly “reducing the wait list” per the CMS guidance, at least it could serve as a bridge for families while they are waiting for a DD Waiver slot.