Virginia Regulatory Town Hall
Agency
Department of Medical Assistance Services
 
Board
Board of Medical Assistance Services
 

160 comments

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6/14/21  9:06 am
Commenter: Cynthia Minto, Richmond Residential Services, Inc.

FMAP Funds
 

We would like to ask that you consider that the increase in FMAP funding should be used to allow providers to address specific problems related to their operations.  Subsequently, we would request for the limited time that this “one time” funding is available it will bridge the January 2022 increase in the minimum wage, until the rebased rates are available. Additionally, it should be simple to access and also be cognizant of the fact that all providers have a unique needs and that there is not a one-size fits all approach. This would be the best way to allocate the funds to address the immediate needs of providers. 

CommentID: 99096
 

6/14/21  3:53 pm
Commenter: Jim Melancon, Aveanna Healthcare et. all

Private Duty Nursing providers proposed use of ARPA funds for home and community based services
 

As private duty nursing (PDN) providers and advocate representatives in Virginia, we respectfully submit our concerns and recommendations for you to consider allocating federal funding provided through the American Recovery Plan Act (ARPA) to states to support Medicaid home and community based services (HCBS) to providers of skilled and private duty nursing services.

Prior to the COVID-19 pandemic, private duty nursing providers have always been instrumental in ensuring medically fragile patients have access to quality care. The care provided by these nurses enables patients, many of whom are Medicaid beneficiaries, with complex medical conditions to remain at home where studies show, and experience proves, they have a better quality of life and often remain healthier than if they were cared for an institutional setting.

The delivery of medical care in the home by nurses also creates a cost-savings to the Commonwealth. The spread of COVID-19 in institutional and congregate living settings, has made home care an even safer model of care for these incredibly vulnerable patients. Throughout the pandemic, private duty nursing providers have collaborated with hospital systems to bring patients home sooner and have worked hard to keep this population at home to reduce exposure to COVID-19.

The need for access to care has not changed in Virginia during the pandemic, yet the risk and costs to provide this care continue to place additional challenges on providers. The challenges include providing additional and new types of PPE which are not reimbursable; convincing nurses to continue to provide in-home care where they work longer hours in a setting less controlled, and less regulated than a hospital, and must do so at a hourly rate far lower than hourly rates paid by hospitals and others.

As you know, the hourly rate paid to Medicaid private duty nurses is determined using a benchmark rate that was established in 2016 through an actuarial study. The hourly rate paid today is just 80% of a 2016 benchmark rate that is well below the private and Medicare rate. Medicaid private duty nurses are being recruited by hospitals, nursing homes and now vaccination clinics. The differential in the hourly rate paid to private duty nurses has been exacerbated during the pandemic with the addition of hazard pay and/or retention bonuses that hospitals and others are offering to nurses. Private duty nursing providers simply cannot compete.

Our inability to compete has impacted patient care. In central Virginia, a 62-patient waitlist for PDN services exists. Patients on the waitlist are either receiving none of or a portion of the PDN authorized services because a nurse is not available to provide all authorized hours. A provider reported 60% of authorized hours are staffed in Richmond and 70% of authorized hours are staffed in Charlottesville. The lack of nurses also impacts the discharge of patients from PDN. Recently 8 of 13 patients discharged by a provider were due to insufficient staffing.

While we understand and recognize that the pandemic has impacted all health care providers, we respectfully ask that you consider using federal funds to provide a rate enhancement to private duty nurses caring for Medicaid patients, as you did for other home care providers including home health care workers and personal care attendants.

On May 13, 2021 we reviewed guidance from CMS articulating how state could use the 10% FMAP increase for home and community-based services and noted that the guidance explicitly states that the funds can be used to support private duty nursing services. Further, the Biden Administration has proposed an ongoing increase in funding for Medicaid home and community-based services. The availability of federal funds enables the state to provide a rate enhancement for a service that is now underpaid and creates cost-savings to the state.

We ask that as you consider our request to use federal funds to enhance the rate paid to the skilled in-home providers of nursing that care for Medicaid’s most medically fragile patients that you remember:

• Private duty nurses are jeopardizing their own and their family’s health because they are committed to ensuring their patients have the care that they need
• Nurses providing care in patient homes reduced the number of patients in nursing homes and assisted living facilities where we know COVID-19 has killed many vulnerable Virginians
• Other states, including our neighbor state, North Carolina, Washington state and others are using the 6.2% FMAP and the HCBS 10% increase to enhance private duty nursing rates. Washington state has increased the rate paid to PDN providers by $6.00/hour.
• A domino effect occurs when patients are unable to access PDN care. Without access to a nurse, family members are forced to stop working to care for their medically fragile loved ones. Unable to work, many families are forced to use other state provided social services and financial assistance programs.

We will continue to work to ensure Virginia’s most medically fragile population has access to in-home care to avoid hospital admission and nursing home placement that could create increased exposure to COIVD-19. We respectfully ask that you help us meet the unexpected and increasing cost of caring for the population.

Please feel free to reach out to us for further information or questions/discussion.

Respectfully Submitted,
Jim Melancon, Aveanna Healthcare
Tracy Colvard, Maxim Healthcare
Roberta Verville, Thrive Skilled Pediatric Care

CommentID: 99109
 

6/15/21  9:46 am
Commenter: Virginia Association For Home Care and Hospice

Medicaid Personal Care, Respite, Home Health, Private Duty Nursing
 

The 10 percent enhanced FMAP for HCBS comes at a time when additional funds are critically needed.  Unfortunately, HCBS providers have not benefited from an increase payment to offset increased cost associated with the COVID response or a corresponding loss in revenue.  This means that HCBS providers have not had an opportunity to invest in infrastructure needs, such as telehealth or other efficiencies that will better position the market for future responses to public health emergencies. 

Because of the limited time ARP HCBS enhanced FMAP funds are available there isn’t an opportunity to invest in long term projects or changes that will incur ongoing general revenue cost after the HCBS enhanced FMAP is no longer available. Therefore, we recommend that Virginia state policy makers

  1. Pursue a strategy that will maximize reimbursement for personal care providers, allowing them to hire and train staff to meet critical needs in local communities.
  2. The rate increases should be retroactive to April 1, 2021
  3. The directed payments provisions of 42 C.F.R. § 438.6(c) should be invoked to ensure that increased funds are indeed distributed to managed care and passed along to personal care providers

 

CommentID: 99112
 

6/15/21  1:09 pm
Commenter: Anonymous

AG Communities
 

AG communities have been heavily impacted by COVID 19 expenses that occurred after Oct 31, 2020 and continue to be today.  I think helping to reimburse for those expenses is much needed to help support those providers and to encourage them to keep communities open. We have lost over $250k in the last year which has limited our ability to care for our residents and has made us question our continued presence in VA.  These residents need services - 

Additionally, there needs to be funds set aside for providers to attract and train candidates for Direct Care and Medication Aide positions.  The amount of trained candidates has declined in the last year and the demand on our industry has not.  We need to be able to incentivize people to check out careers in working with seniors and disabled adults and then support them through getting the training that they need. 

CommentID: 99114
 

6/15/21  1:10 pm
Commenter: Dorothy Nicholson

Help Medicare folks
 

Saddens me that Medicaid recipients pay no co pays , or monthly enrollments fees and a lot of them are young healthy women popping babies . Stop giving them hand outs and encourage them to work and help the elder and disabled who live on a meezley 900 a month . VA should not encourage lazy people they should focus on those who paid in all their lives for benefits that benefit people who have never worked at anything but making kids they can’t afford . HELP MEDICARE take away out copays and fees give us dental and vision . YOU OWE US 

CommentID: 99115
 

6/15/21  1:16 pm
Commenter: Anna Smith

Mental Health and Substance Abuse Care
 

I personally struggle with groups or going anywhere as I have agoraphobia. I’ve been doing Telehealth for my appointments and love it. I think more Telehealth would help especially people like me.

CommentID: 99116
 

6/15/21  1:35 pm
Commenter: S Williams (agency patient/ ventilator dependent)

Pay increase for home health nurses
 

Please pay our nurses more so agencies can compete with facilities. There is no incentives for new new nurses or any nurses to want to do home health. We home health patients need quality nurses who want to be here. Most of our nurses have to work multiple cases just to make ends meet. Most of them are over worked and under insured which makes the problem for everyone even worse. 

As a tracheotomy and vent dependent patient, our nurses need better training. I don’t know if that needs to be done in the educational programs or if that should be the agency’s responsibility but it needs to be done. And if it can’t be done, make it easier for our loved ones to get paid because they’re the ones who are left providing care when they’re no nurses available which is often.

Most agencies in the Richmond area, don’t have nurses available. We need help!!!!

CommentID: 99118
 

6/15/21  1:37 pm
Commenter: Anonymous

assisted living
 

consider expanding assisted living eligibility.  specifically the income test and the AG maintenance need.    Other (Northern) states have a broader income test and  this allows clients more access to supportive care  and can then sometimes avoid  inpatient nursing home  care.....which we know is far more expensive. . 

CommentID: 99119
 

6/15/21  1:39 pm
Commenter: Anonymous

Day Support
 

The fund need to go towards at-risk individuals in day support and getting them back to day support instead of languishing at home.  My son's program is prioritizing individuals that live in group homes that they own and just doesn't seem right to me.  They have not kept in touch except to mail quarterly reports.  It irritates me that they are being paid to NOT provide services to my son who falls in the severe range of ID but is not medically fragile.  He had just finished his 60-day assessment right before the shutdown.  He was already languishing at home for most of 2019 after graduating from high school in 2018. Zero efforts were made to do anything creatively at the day program where he is a "participant".

  1. Day programs can do telehealth services or community engagement with the higher functioning and let the lower functioning that don't benefit from video calls to come for face to face.
  2. Pay Day Programs a higher rate, if they do 1:2 community engagement instead of 1:3.
  3. Allow Community Coaching 1:1 for individuals who don't have behavioral needs but can't do 1:3 community engagement due to safety issues related to their level of ID.
  4. Allow community engagement to start and end services from the person's home so they don't need to come into the center and mix with the participants who are not in community engagement.
  5. Allow community engagement to use volunteers to increase ratios so that lower functioning participants can have a 1:1 for safety needs (looking for traffic, staying with the group, not going off with strangers, or maybe help with personal care while out.)  Motivecare uses volunteer drivers so why can't day programs use volunteers to bring ratios to a manageable level so that even the more intensive participants can go on community outing?
CommentID: 99120
 

6/15/21  1:41 pm
Commenter: Parent

Caregivers
 

I believe the extra funds should be used to help increase pay for Attendants.  During the pandemic, I lost several attendants because of safety concerns and unemployment benefits were paying better than $9.44 an hour that VA Medicaid does for Attendants.  Now that things are getting better, I am still finding it hard to hire attendants for my 2 children with special needs because fast food restaurants are paying $15 an hour and some include benefits.  In order for us to keep or hire quality attendants for our children and/or adult children, the pay needs to be comparable.  Attendants work very hard and during the pandemic put the needs of their own families aside to help us and our family members stay in the home.  

Additionally, funds should be used to start, build, or further enhance job opportunities and adult supports for people with special needs - especially in RURAL areas.  Those who live in rural areas are very much overlooked and have very limited resources, if any at all.

CommentID: 99121
 

6/15/21  1:43 pm
Commenter: Rhonda Ruff

Budget Suggestions for Increased Funding
 

The area I most feel a gap in support as a single working mother of a disabled child is the ability to find qualified, dependable, reliable, and long-term attendants for personal care and respite hours so that I can continue to work. The hourly rate is too low for working adults who could provide the level of care our children need. The pay rate, especially for Albemarle County, needs to be raised to attract better caregivers. A living wage is necessary for them to commit long-term. A move towards $15/hr is much needed.

It has been a huge relief and a Godsend for DMAS to allow parents to be paid attendants during the pandemic. Beyond losing jobs due to the pandemic, there are times when mothers are forced out of the workforce simply because of the increased demands of their disabled child(ren) and lack of flexibility at work. It should be an option for mothers (or fathers) to be the primary paid attendant should they deem it impossible to find adequate support elsewhere or if they feel they are the better option. In my case, it has been difficult to train attendants to provide the same (or nearly the same) level of care that I can provide myself. It has also been an area where I have had to entrust my child to less than desired caregiving to maintain my job because of the lack of available and qualified attendants who are as dedicated to the work as I am.

Please keep this option of being the paid attendant open to parents! It has made a life-changing difference in the stability of our family and my child's development over the last year.

The other areas of funding that are currently missing are funding for out-of-network providers (ST, OT, PT, LPC, counselors, psychiatrists, etc.). In my town, very few providers are in-network for any of the insurance companies or Medicaid. Getting high-quality support in these areas for our kids is very tough if you don't have deep pockets. Waitlists are long for in-network providers.

CommentID: 99122
 

6/15/21  1:43 pm
Commenter: Ann P

funding to cover Music Therapy as an in home service
 

Music therapy is helping a lot of kids and adults with disabilities but this program can only be accessed privately or offerred at hospital when in patient.

Please include this program as a type of therapy that can be delivered at home.

CommentID: 99123
 

6/15/21  1:47 pm
Commenter: Willard Vaughn, The Milieu Therapeutic Services

Community Response or Telehealth
 

One way this money could be used is to allow private agencies to provide crisis and wrap around services to individuals in need.  Per regulations, an individual can be seen a certain amount of time and billed as a crisis intervention before requiring a treatment plan.  This funding would help support such agencies that would want to do something of this nature with infrastructure and equipment in order to do so.  

Another idea would be to help with Telehealth providers and provide training and support.

CommentID: 99124
 

6/15/21  1:48 pm
Commenter: Anonymous

Provider web portal
 

The provider web portal to check eligibility is antiquated.  Allow for a date range and increase the number of lines to cover an entire year.  Allow providers to check eligibility for more than a year, or at least provide a start date of eligibility.  

Also, there should be a life event or circumstance like private insurance does, to prevent switching of plans back and forth.  Some patient switch every month.  This leads to excessive costs for claims, refunds, etc. Have an open enrollment period for Medicaid patients to be able to change their plan.  Maybe twice a year as opposed to every month.

Provide more education to patients so that they understand the dental, vision, and hearing aid coverage and how to select a participating provider.

Eliminate patients over child bearing age from selecting Plan First coverage.  A 60 year old female gets no benefit from Plan First coverage.  

CommentID: 99125
 

6/15/21  1:54 pm
Commenter: Julius Smith Hampton Newport News Community Services Board

Extension of Medicaid Reimbursement for Telephonic Outpatient Therapy and Medication Management
 

Based on feedback from clients and increased ability to serve clients during the COVDI19 Pandemic flexibility period, I believe that making a provision for Medicaid to extend Reimbursement for Telephonic Outpatient services would allow us to service more clients that had the barrier of transportation removed by the ability to receive therapy/medication management services Telephonically. It is concerning that those clients whom do not have access to smartphones with reliable cellular networks would not longer have access to treatment remotely (since effective Zoom Telemedicine sessions require a capable smartphone and good cellular data services to be effective).  My concern is that No Show and Cancellation rates may fall to levels worst than they were Pre-Pandemic due to many factors some pre-existing and some COVID related (specifically, the inability of clients to rely on public transportation due to the amount of time it takes to get to and from sessions is a barrier to treatment i.e. a client expressed that it would take him 1.5 hours to get to a visit and the same time back thus 4 hours out of this person's day had to be dedicated for a one hour session which provoked No Shows and Cancellations in the past, Medicaid cab inconsistency has been an issue that has contributed to cancellations and No Shows previously, fear of exposure to COVID is a still current concern for some clients).Overall, extending Telephonic Outpatient Services would broader our reach Long Term and make access to Mental Health services more Equitable.

 

Julius Smith, LPC

Adult Outpatient Clinical Services Manager

Hampton Newport News Community Services Board

 

CommentID: 99126
 

6/15/21  1:55 pm
Commenter: Aasta Pauley RN

medication management/monitoring for behavioral clients; ABA therapy funding for children
 

I find in conducting the LTSS screenings for adults/children with behavioral health needs that many do not meet the criteria for this waiver.

  • Young children and parents need access/funding to pay for much needed ABA therapies.
  • Adults need medication management/monitoring (but functionally are independent).

It would be nice to see these gaps bridged.

CommentID: 99127
 

6/15/21  1:55 pm
Commenter: Kelly Kendrick

Substance abuse and recovery
 

This pandemic has significantly increased relapse and addiction across the world.  Particularly in Virginia. Recovery can come in many forms but counseling is a huge part of it all. Due to covid, groups and counseling are few and far between.  This and MAT programs are so hard to find now days.  This is going to cripple our state.  Finding good health care is hard to find now days.  Many of these mat programs only allow cash so those with insurance that can't afford $200-$500 a month are put in a bad situation.

CommentID: 99128
 

6/15/21  1:58 pm
Commenter: Anonymous

Expand Personal Care Services for Greater Recruitment and Quality of Life for Your Members
 

I have 70 hours currently approved through my MCO and service facilitator, but I am still encountering significant barriers. I've had phone interviews with several candidates, and most have not shown for the face to face interview. Transfers are a vital ADL next to bathing, dressing, and toileting; I have a walker in my home in addition to my power wheelchair, but I can't use a gait belt, transfer board, or Hoyer lift in or out of my house due to space constraints. I am aware of the safety risks that may occur and have been working to identify other alternatives, but accessibility is still a barrier and not always guaranteed. The hourly rate paid to a Consumer-Directed Attendant is $10.50 per hour (which is some progress in the last 17 years as a recipient) but Medicaid regulations only allow one caregiver to work a 40-hour max per week. Right now, both of my parents are working that max between 6AM-11PM, which means she can fully enjoy her retirement. 

CommentID: 99129
 

6/15/21  1:58 pm
Commenter: Dixie Wilson, Northwestern Community Services Board

Increase eligibility for Medicare/Medicaid QMB Limited and SLMB categories
 

I have worked at Northwestern Community Services Board for almost 20 years.  I work primarily with adult clients and benefit eligibility.  Many of our clients receiving Social Security Disability Benefits for a serious mental illness have a monthly benefit amount ($1,064 - $1,436) that makes them ineligible for full Medicaid coverage.  Most of these clients would benefit from case management, psychosocial rehabilitation, and ACT services with a medical necessity determination.  They have to meet a very deductible amount every 6 months to satisfy their spend down amount.  Medicaid Expansion is providing full coverage to low income individuals through the Medicaid Managed Care Organizations.  An individual can have a monthly income of $1, 481 and qualify for Medicaid coverage.  Medicaid Expansion members may or may not have a debilitating serious mental illness and yet, they are able to access targeted case management services for assistance in linkage to community resources, attend/participate in psychosocial rehabilitation programs, and receive ACT services if more intensive services are required.  When providers such as CSBs, provide these needed services to those with Medicare/Medicaid spend downs, there is no reimbursement in most instances due to the difficulty of meeting these very high 6 month spend down amounts.  These individuals with SMI's would benefit greatly by having access to the Medicare non-covered mental health services, and providers could be reimbursed for such services.

Thank you,

Dixie Wilson

Eligibility Benefits Specialist/Credentialing Specialist/NWCSB

CommentID: 99130
 

6/15/21  2:15 pm
Commenter: Joanne A Greene LCSW,

Increased access to mental health providers
 

I am newly retired from full time work after providing mental health services for many years at a Federally Qualified Community Health Center.  I had agreed to continue to see about 15 of my long term, SPMI patients, all of whom are Medicare and/or Medicaid recipients.  When I discovered that my credentialing would not follow me  into a private practice, I sought out contracting with the managed care organizations and I was disappointed to learn that they were not interested in developing new contracts.  So, I am providing mental health services on a pro bono basis to patients who need this service and can not (or refuse to) see another provider. Please consider strongly encouraging the MCOs to be more flexible about their contracting.

CommentID: 99131
 

6/15/21  2:24 pm
Commenter: Sarah Blunkosky, MA, RYT

Increase Attendant Pay For Equity and More State Jobs and more
 

Medicaid funds can help boost local and skilled jobs, raise pay to $15 an hour to provide a living wage for skilled employees to provide for families with benefit options partnered with state agencies and state businesses (money funds jobs and state and local businesses so it's a win win).  Skilled care giving is ESSENTIAL as we learned in pandemic and levels up local life- quality care, quality supports for families, quality job pay -spills back into community- COMMUNITY BASED CARE. 

Funds can also be allocated to Medicaid Waiver recipients to spend locally and in state (tax dollars staying in local and state) and with these funds, family can purchase essential and helpful care and support items not covered by insurance. Funds will support families and go into local and state businesses.

 

 

CommentID: 99132
 

6/15/21  2:30 pm
Commenter: covid19 side effects linger

Lingering non life threatening effect
 

The pandemic may have lingering hidden health issues, both physical and mental. 

Please consider expanding healthcare insurance coverage for those items. 

For example, through conversation, people that are trying to get back to normal life pre pandemic is running into difficulties.  The virus may have inserted long term side effects such as mood swing, anger, confusion, sleep problems, hallucinations, feeling restless or irritable, depression, memory weakening, hives, difficult breathing, sore throat, burning eyes, skin pain, blistering and peeling, blood vessel inflammation, weak or tired, tingling or numbness in arms or legs, stomach pain, diarrhea, trouble hearing, headache, and other minor but painful symptoms.

Some people may feel forced to live with these side effects because they don't want their employer to know, risking job termination.

Let's look into these things?

CommentID: 99133
 

6/15/21  3:04 pm
Commenter: Anonymous

Pay
 

Hourly rate of pay needs to be increased for workers who provide care in the home. These workers do the work that nobody else wants to do and by doing so help keep patient from going to nursing homes which would cost even more .

CommentID: 99134
 

6/15/21  3:08 pm
Commenter: Thomas Schuplin

Team-Based Coordinated Specialty Care
 

Utilize funding to add Coordinated Specialty Care (CSC) for First Episode Psychosis to the array of services funded by Medicaid. Funding should cover all services provided by the CSC team. Funding can be used to either develop a SPA or a 1115 waiver project.

CommentID: 99135
 

6/15/21  3:52 pm
Commenter: Carole Lynch

Dementia Patients
 

Increase funding to help enable families to provide care in the home versus institutional care.

CommentID: 99136
 

6/15/21  3:56 pm
Commenter: Adult day care

Increase reimbursement rate for ADC/ Adequate regulation of patient pays
 

-There has not been an increase in the reimbursement rate of Adult day centers for at least 5 years or more.  We have operated at a deficit for a long time.  As the minimum wage rate is now being increased the reimbursement rate needs to be increased as well.  The Government currently pays a minimum of $100 per day for adult day services. Without an increase in the rate, and a continual increase every year until $15/hr, will indeed be detrimental.  Our service we provide to many families is a Godsend.

 -Patient pays should only be recouped from one entity.  A client typically pays their patient pay at the beginning of the month to 1 agency, and that is where the patient pay should be re-couped. The changed and more recent practice of DMAS recouping these payments from any provider they deem leaves agencies at a loss, and/or trying to recoup monies from another agency, or the client.  

CommentID: 99137
 

6/15/21  3:57 pm
Commenter: Whitney King, MAT, PBS-F

Additional Pay for DSPs & Direct Care Staff
 

The funds should be granted to DSPs and all of the people who work endlessly with the people receiving supports in VA. These regulations change daily only to increase paperwork, but at the core the DSPs continue to give their all and the people who need supports are cared for because of their dedication.

CommentID: 99138
 

6/15/21  4:05 pm
Commenter: Mattie Bowman

Pharmacy /Prescriptions
 

Please expand Medicaid services. Prescriptions not approved prescribed by your doctor or refund to customers monies already spent for proper care. Dental and vision care need to be expanded as well.

Thanks for listening 

CommentID: 99139
 

6/15/21  4:09 pm
Commenter: Teena Lovern, LPC, NCC, BC-TMH

increased oversight for existing services; improving access
 

Funds should be allocated for more QA/oversight of existing Medicaid-funded behavioral healthcare services.   There isn't enough space in this forum to 1) describe some of the non-justifiable practices being billed as clinical services; or 2) to ponder the mysteries of why no other insurer will cover these services -- only Medicaid, as if only the poorest of the poor have problems for which wraparound supports are necessary.  Perhaps 1 explains 2.  Regardless, this is folly.  Auditors should focus less on how agencies/providers prove they are doing the work (chart audits), and more on conversations with consumers about their experiences.  These conversations inform my belief that widespread incompetence (at best) and outright fraud (at worst) is rampant throughout the Commonwealth.

Since so many Virginia seniors with identified behavioral healthcare support needs are just a few dollars away from being Medicaid-eligible, outpatient counseling is typically their only option.  But the waiting lists are long -- so many providers are (still) only offering telehealth services and many seniors are not comfortable with this, have access issues, and/or cannot afford copays.  Virginia and the rest of the country could easily address the provider shortage/access issue by passing Medicare Reimbursement Legislation (link) permitting Licensed Professional Counselors (LPCs) to be reimbursed by Medicare.  Finally, we cannot go wrong by improving every low-income Virginian's access to technology, so (especially where/when only telehealth options exist) we could provide training and/or tools (including but not limited to devices and internet service) to enable them to access healthcare.

 

 

CommentID: 99140
 

6/15/21  4:14 pm
Commenter: Gerry Rawlinson

FMAP
 

FAMP one time funds should be used to increase all CCC Plus Providers' reimbursement rates by 10% effective July 1, 2021.  This additional funding will support Providers to offset the increased cost associated with May 1, 2021 and upcoming January 2022 minimum wage increases.  

The minimum wage increased by 31% on May 1, 2021.  In order for Providers to be competitive in the hiring of qualified staff, reimbursement rates must be alignment with the Provider's cost.

 

CommentID: 99141
 

6/15/21  4:26 pm
Commenter: Pam Oswald, RN BSN, CCM

Provide SNF benefit for Medicaid Members
 

Members with Medicaid only are often denied SNF benefits which leaves them to return home from a hospital stay in a debilitated condition which increases the likelihood of rehospitalization due to a fall, not take their medication correctly or just be too weak to care for themselves. 

 

CommentID: 99142
 

6/15/21  4:29 pm
Commenter: Pam Oswald, RN BSN CCM

Increase payment to Home Health Agencies
 

Medicaid does not reimburse Home Health Agencies as much as Medicare does, therefore Medicaid members are often denied services in favor of a Medicare member due to finances alone.

CommentID: 99143
 

6/15/21  4:40 pm
Commenter: Dante Bailey

Waiver and attendant care
 

They need better pay for the attendants 

CommentID: 99144
 

6/15/21  5:07 pm
Commenter: Jacqueline Igoe

Improvements to CCC+ waiver
 
  • Increase access to HCBS services and supports:  Ease co-insurance burden on potential CCC+ participants whose income approaches the CCC+ maximum.  Since rent and other benefits are also based on income, those with high co-insurance payments often cannot afford them and still meet their other monthly necessities. 

 

  • Invest in technology and HCBS infrastructure: troubleshoot electronic log-in of aides for those areas that have no internet service (mountainous areas, basement apartment, for example) 

 

  • Improve or support high-quality care and the member experience with HCBS services: provide subs when an aide is sick or on vacation; client and family in-put into plan of care and the daily schedule.  More oversight of new cases by experienced aides or other supervisors. Offer training in dementia care, culture-specific cooking; how to arrange transport; English language skills; basic housekeeping, etc.. Unannounced staff checks to see that aides are actually present w/ client and engaged in relevant activity.  Consider quality of life: Provide weekend hours where ct wants/needs them. Some clients may need assistance to get to and participate in religious service or other family/community events on weekends, yet most agencies cannot staff weekends. Provide gloves, gowns, and whatever PPE aides need.  Most aides and their patients cannot afford to purchase these on their own.

 

  • Develop and build the HCBS workforce, including recruitment and retention strategies: offer cash bonus to new aides who train and successfully complete a year of service; provide support, extra supervisory visits for in-person instruction for new aides; Provide aides health insurance, PTO and a living wage.  Offer financial incentives to complete additional training, demonstrate new skills. 
CommentID: 99145
 

6/15/21  5:34 pm
Commenter: Anonymous

Specialized Modality
 

I would suggest Medicaid covering services such as play, art, music, and equine, and resilience skill building/trauma therapy. To increase more providers that are specialist in different forms of therapy (i.e. more CSOTP-sexual offender therapy). To cover specialized psychological to include (neuropsych's). To review evidence based programs that can be contracted thru Medicaid. 

CommentID: 99146
 

6/15/21  6:39 pm
Commenter: Shelley States

Dental health
 

Provide more dental benefits to recipients. Dental issues can cause major health issues, yet are either not covered at all or barely covered. Lowe income residents forgo dental care due to this, which ultimately causes medical claims to be higher. 

CommentID: 99147
 

6/15/21  7:17 pm
Commenter: Bena Family Care Facilitators

Parents with children on DD waiver waitlist
 

Over the past 20 years I have worked as a DSP and in care coordination with VAAA Cares for UHC and am currently in the process of becoming a certified Facilitator for CCC Plus and IDD waivers. Because of my work experience the community, family and friends often contact me for help navigating how they can get the supports they need. Recently I have been assisting a close friend with qualifying and applying for much needed support of her adolescent child who has Autism who is currently on the DD waiver waiting list.

Mandate that other support waivers are offered while on the waiting list

I would like to propose that it be mandatory for agencies to assess these individuals for enrollment to other support waivers ie. ("Coordinated Care","Family & Individual Support",  "CL" waiver) to supplement support needed while on the waiting list. As children grow and develop their needs often time become more intensive. In the interim of waiting the individual is missing crucial opportunities for social skills growth and development. Often times these individuals are experiencing behavioral changes, parents may have a chang in income and employment as well as issues with housing. Therefore the urgency of need increases.

Protect parents' employment

I would like to also propose new employment protections for parents with children diagnosed with Disabilities. Often parents must utilize time away from the job to go to IEP meetings, transport their child to therapies, facilitate socialization and learning opportunities, or intervene in crisis at school. This often limits their abilities to seek and accept more substantial income or they are in fear of losing employment.

 

CommentID: 99148
 

6/15/21  7:29 pm
Commenter: Better health through sustainable and innovative way.

Support culturally tailored and adopted senior care service and management at community home and fac
 

I have witnessed there are less support available for seniors to remain in community home than institutional facilities here in northern Virginia especially seniors who are from diverse background. Senior care would be all different from culture to culture but the foundation is not different. Although they are potentially capable to remain at community home with some supports and modification, many ends up to long-term facilities due to medical and non- medical reasons such as 24 hour supervision, environment, ADLS, and so on. And seniors often deteriorate independent abilities while covering one area. Often family and caregivers also is overwhelmed with no knowledge supporting elders who would need assistance in ADLs.

I want to set up a program for seniors in culturally diverse area, the program assists them to be able to remain safe at home or residential setting by providing and filling the gaps that other commercial providers often cannot afford or missed because it is not billable. Please create fund and make the process easy for health care providers who pursue community friendly senior care. I would like to seek for available  fund to implement the program(CAPABLE) for the northern Virginia community providing modification in home environment, OT and RN service. Eunjung Suh RN, MSN 
 

CommentID: 99149
 

6/15/21  9:59 pm
Commenter: CT

Lack of in network availability for psychiatry and clinical psychology with certain MCOs
 

MCOs such as ABHVA have little to no availability of any in network psychiatrists and clinical psychologists. This service delivery failure then forces various Medicaid members to initiate Good Cause Change Requests so that those members can access an MCO who has a wider and deeper selection or simply a selection of some kind.

Also, certain providers in clinical psychology will provide testing for Level 1 HFA or other testing but they never produce a report on the testing which forces the member to contact SSA, DDS, a disability attorney, and other clinical practices to contact the uncooperative practice so that some type of a report and diagnosis is generated. Being forced to go through such a process is an ordeal for the member. Best practices should mandate that such business practices do not take place at all. 

CommentID: 99150
 

6/15/21  10:06 pm
Commenter: CT

Medicaid members being forced to deal with LPCs, NPs, and PAs but no access to MDs, DOs, and PhDs
 

LPCs have significant limitations on what they can recommend and implement. When the Medicaid member has little to no alternatives through certain MCOs, the recommendations of the LPC such as DBT, SFT, directed therapy or many other forms of treatment are not available to those Medicaid members. 

CommentID: 99151
 

6/16/21  8:21 am
Commenter: Anonymous

Allow at least one parent to be a caretaker for a child with disability
 

Allow at least one parent to be a caretaker for a child with disability, it helps in a BIG way to the family.

CommentID: 99153
 

6/16/21  8:24 am
Commenter: Annie

DD Waiver
 

DD Waiver Access and Services. No IFSP Funding so far in 2021. 

CommentID: 99154
 

6/16/21  8:38 am
Commenter: Anonymous

Please Clear DD Waiver Waiting List
 

Please clear long waiting DD waiver list.

CommentID: 99155
 

6/16/21  9:14 am
Commenter: Anonymous

Dental Coverage
 

Providing Medicaid recipients Dental coverage. Offering Dental care will help prevent major health problems such as; Cardiovascular issues. That results in more and higher Medical Claims and/or disability that leaves the recipient impaired.

CommentID: 99156
 

6/16/21  9:58 am
Commenter: Anonymous

Mobile Unit
 

Better access by rotating and placing in every low income a Mobile unit that could be available during the day or evening up 6 pm.There are still single mothers with no transportation. It would reduce non emergency issues going to the hospital and they could be screened before they go to the  children's hospital.

Proper medical and Dental referral could be made according to the needs of the child. 

CommentID: 99157
 

6/16/21  10:10 am
Commenter: Whitney Sparks, AmeriCare Plus

Medicaid Personal Care
 

We respectfully request the 10% Medicaid increase FMAP for HCBS Medicaid Agency Directed Personal Care Providers as this program is not adequately funded to care for the Commonwealth’s most vulnerable populations.    Agency Directed Personal Care Providers have already incurred the increased costs associated with COVID-19 and the loss of revenue due to COVID-19 and have been impacted by the minimum wage increase that took effect May 1st.  Agency Directed Providers are facing an additionally unfunded minimum wage increase on Jan 1, 2022, which will further jeopardize their ability to continue to operate and provide these crucial personal care services to the citizens of the Commonwealth.  These Agency Directed Personal Care services offer tremendous costs savings to the Commonwealth over the same recipients receiving care in nursing homes.

In order to continue to provide this invaluable care to the Commonwealth’s most vulnerable populations we recommend Virginia State policy makers:

  1. Pursue a strategy that will make maximum reimbursement for Personal Care Providers allowing them to hire & train staff to meet critical needs in local communities.
  2. The rate increases should be retroactive to April 1, 2021.
  3. The directed payments provision of 42 C.F.R. 438.6 © should be involved to ensure increased funds are indeed distributed to Managed Care & passed along to Personal Care Providers.

 

Sincerely,

Whitney Sparks, Medicaid Specialist 

AmeriCare Plus In-Home Personal Care Agency

CommentID: 99158
 

6/16/21  12:08 pm
Commenter: kristina

63% of Dentists refer patients to an Endo - Adults NEED Comprehensive Dental & Restorative Care
 

According to the American College of Prosthodontics 64% of general dentists refer patients to an endodontist and 44% to a periodontist. However state medical/dental benefits, do not offer dental benefits (other than X-rays once a year and extractions) , despite the cost of routine dental care and prevention along with endo care when necessary and dentures or implants for those who have had severe decay due to cancer or a rare disease diagnosis or the treatment causing tooth decay, Medicaid should offer implants, bridges or dentures and not just extractions - for health reasons, and so that people will receive treatment. 

Without proper treatment, then antibiotics and pain medicine is prescribed when the person without comprehensive dental has a filling fall out or an abscess (because without having insurance to help pay for a root canal and crown, no one is just going to have their teeth removed when antibiotics and numbing medicine is the better option- until it happens again)

According to the CDC, when this keep happening, and tooth decay spreads and can cause severe infections, sometimes fatal. Gum disease is the main result of the inflammation and can increase risk to diabetes and cancer.

It seems counterintuitive for the state to stop providing dental care at the age of 19. Dentists in Virginia often schedule cleanings for adults, but take the X-rays and go over a consult by telling them what work they need done before even have a hygienist in to actual do the preventative work. Most adults leave either because they’ve run out of time and need to get back to work or leave out of fear. Regardless they still just have their dental records recorded, not even the bare minimum work of the cleaning, which then further contributes to cavities at first, but it’s not like they have the benefits and it’s not like they received the cleaning they were supposed too, so why would they go back 

Bottom line,Full dental coverage is important for the health, economy, and self - inside and out.  

Add comprehensive dental coverage, or at least implants with extraction coverage, and the endo treatment isn’t necessary, but the problems in between for adults are causing health issues.

 

CommentID: 99160
 

6/16/21  1:15 pm
Commenter: Dana Howell AmeriCare Plus, LLC

Medicaid Personal Care
 

We respectfully request the 10% Medicaid increase FMAP for HCBS Medicaid Agency Directed Personal Care Providers as this program is not adequately funded to care for the Commonwealth's most vulnerable populations.  Agency Directed Personal Care Providers have already incurred the increased costs associated with COVID-19 and the loss of revenue due to COVID-19 and have been impacted by the minimum wage increase that took effect May 1st.  Agency Directed Providers are facing an additionally unfunded minimum wage increase on January 1, 2022, which will further jeopardize their ability to continue to operate and provide these crucial personal care services to the citizens of the Commonwealth.  These Agency Directed Personal Care services offer tremendous costs savings to the Commonwealth over the same recipients receiving care in nursing homes. 

In order to continue to provide this invaluable care to the Commonwealth's most vulnerable populations we recommend Virginia State policy makers:

  1. Pursue a strategy that will make minimum reimbursement for Personal Care Providers allowing them to hire and train staff to meet crucial needs in local communities.
  2. The rate increases should be retroactive to April 1, 2021.
  3. The directed payments provision of 42 C.F.R.438.6 (c) should be involved to ensure increased funds are indeed distributed to Managed Care and passed along to Personal Care Providers.

Sincerely,

Dana Howell, HR/PR Specialist

AmeriCare Plus In-Home Personal Care Agency

 

CommentID: 99162
 

6/16/21  1:23 pm
Commenter: Nicky Fadley, Strength In Peers

Pilot payment options for peer recovery support services
 

Medicaid regulations significantly limit the ability of peer-run Recovery Community Organizations (RCOs) to access Medicaid reimbursement for peer recovery support and family support partner services. Scientific evidence shows that these services are effective at addressing mental and behavioral health challenges. Much of this evidence comes from research into peer support services provided by non-clinical, peer-run organizations that are the founders and champions of a peer recovery movement dating back almost a century. Unfortunately, regulations were designed to only provide reimbursement to clinical treatment facilities that include peer support services. As a result, RCOs are entirely dependent on grants and donations that are often not sustainable. 

Expanding access to peer support should be a priority for Virginia, particularly the growth and sustainability of peer-run RCOs that are BIPOC-led and LGBTQ-led, as well as located in rural, inner-city and other communities experiencing behavioral health disparities. We recommend that DMAS use available funds to pilot new Medicaid payment mechanisms to fund RCOs directly for peer recovery support and family support partner services. These pilots should not require RCOs to be sub-contractors of clinical treatment facilities or supervised by clinical treatment facilities. They also should streamline the processes or provide technical assistance to help RCOs register with Medicaid and negotiate contracts with managed care organizations.

Strength In Peers is a nonprofit, peer-run Recovery Community Organization. More than half of our Board of Directors and all staff are in active recovery from substance use, mental health and trauma-related challenges. Our mission is to offer hope, support and advocacy for those seeking recovery so that they can build resilience and thrive in their lives and communities. We operate jail and street outreach, needle exchange and other harm reduction services, HIV and Hepatitis C testing, a community recovery and resource center, and comprehensive integrated peer and clinical recovery programs. We serve between 800 and 1,000 individuals per year across our service area that includes the City of Harrisonburg and the Counties of Page, Shenandoah and Rockingham. 

 

CommentID: 99163
 

6/16/21  1:31 pm
Commenter: Melissa Baugh, Americare Plus Agency Manager

Medicaid Personal Care
 

We respectfully request the 10% Medicaid increase FMAP for HCBS Medicaid Agency Directed Personal Care Providers as this program is not adequately funded to care for the Commonwealth’s most vulnerable populations.    Agency Directed Personal Care Providers have already incurred the increased costs associated with COVID-19 and the loss of revenue due to COVID-19 and have been impacted by the minimum wage increase that took effect May 1st.  Agency Directed Providers are facing an additionally unfunded minimum wage increase on Jan 1, 2022, which will further jeopardize their ability to continue to operate and provide these crucial personal care services to the citizens of the Commonwealth.  These Agency Directed Personal Care services offer tremendous costs savings to the Commonwealth over the same recipients receiving care in nursing homes.

In order to continue to provide this invaluable care to the Commonwealth’s most vulnerable populations we recommend Virginia State policy makers:

  1. Pursue a strategy that will make maximum reimbursement for Personal Care Providers allowing them to hire & train staff to meet critical needs in local communities.
  2. The rate increases should be retroactive to April 1, 2021.
  3. The directed payments provision of 42 C.F.R. 438.6 © should be involved to ensure increased funds are indeed distributed to Managed Care & passed along to Personal Care Providers.

 

Sincerely,

Melissa Baugh, Agency Manager

AmeriCare Plus In-Home Personal Care Agency

 

CommentID: 99164