Virginia Regulatory Town Hall
Department of Medical Assistance Services
Board of Medical Assistance Services
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11/4/21  4:01 pm
Commenter: Brooke Mitchell, Loudoun County MHSADS

Chapter 4 and Chapter 6 Comments

VIDES Discrepancy

Page 3 of Chapter 4 indicates that “VIDES for infants must be used for the evaluation of individuals who are younger than three years of age.  Two or more of five categories must be met.  Vides for children must be used for the evaluation of individuals who are three years of age through 17 years of age.  Two or more of seven categories must be met.”  However, page 6 of Chapter 6 contradicts this guidance by stating the VIDES must “document that the individual meets the dependency level in two or more (for infants) and three or more (for children and adults) of the categories.” 

We recommend correcting this inconsistency in Chapter 6 to reflect the current requirements of two (2) areas for infants and children and three (3) areas for adults. 


SIS Discrepancy

Page 25 of Chapter 4 indicates:

“The SIS or other developmentally appropriate assessment is completed according to the following regular schedule:

At least every four years for those individuals who are 22 years of age and older,

At least every three years for those individuals who are 16 years of age through 21 years of age,

Every two years for individuals five years through 15 years of age. . .

For children younger than five years of age, an alternative industry assessment instrument approved by DBHDS, such as the Early Learning Assessment Profile, will be completed by the appropriate professional every two years for service planning purposes.”

However, on page 9 of Chapter 6, guidance states, “Individuals 16 years or older will have a Virginia SIS® completed every four years or more frequently if the individual has undergone significant changes and those between 5 and 15 years will have a Child SIS® completed every two years.”


We recommend that DMAS amend the Chapters to eliminate any discrepancy regarding the SIS.


Priority Needs Checklist and Critical Needs Scoring


Page 11 of Chapter 4 states, “a review of the individual’s status and a new Priority Criteria Checklist will be completed by the Support Coordinator when the needs of the individual change, but ideally no less than once every three years.”  We are seeking clarification as to the meaning of “ideally” for purposes of this sections.  Should this phrase be interpreted to offer flexibility as to the checklist completion?


Furthermore, page 11 of Chapter 4 states, “the Critical Needs Summary form for each individual on the waiting list must be reviewed and updated annually and whenever the individual’s “critical needs” change.”  We are seeking clarification on the meaning of the term “annually.”  Is this referring to annually from when the last form was completed or annually from when the individual is entered priority 1, when they went onto the waitlist?



Slot Availability


Page 13 of Chapter IV states, “the Support Coordinator must notify the individual and family/caregiver of slot availability and available services within the offered waiver within 7 calendar days of the waiver slot assignment date.”  We have concerns regarding the realistic ability for Support Coordination to meet this requirement. The requirement to notify within 7 calendar days of slot assignment is not typically an issue if there are only a few slots; however, many slots are assigned all at once, this is a challenge.  The information indicates calendar days, which does not account for holidays or weekends.  The assignment date is the date DBHDS moved the individual to “projected” status.  CSBs and Support Coordinators shall make all efforts to notify the family within 7 days; however, there must be a way for CSBs to request an extension based on emergency situations and/or number of slots assigned at once.  Additionally, the Developmental Services Director of each CSB needs to receive notification of slots assigned as a particular Support Coordinator may be on leave.


Page 13 of Chapter IV also states, “the individual or family caregiver, as applicable, will confirm acceptance or declination of the slot within 15 calendar days of notification of slot availability.”  This guidance is vague in terms of what CSBs and Support Coordinators are to do if the family does not respond within 15 days.  We are seeking guidance on actions regarding what actions to take when such situations are encountered.


General Comments


Chapter IV, page 27 and page 44, indicate no more than 365 days (or 366 days in leap year) between ISP dates and updating the ISP.  Please clarify if both refer to the plan dates rather than one being around ISP planning meetings.


The new manual indicates private duty nursing authorization for adults must be done every 6 months rather than annually.  Private duty nursing is a critical service and the administrative process associated with doing the renewals is burdensome on CSBs.  We ask that DMAS please provide information regarding reasoning for this change and ability to revisit to ensure service delivery.


We are concerned about the practicality of meeting notification timelines for initial Waiver assignments (7 days to notify families, 15 days for them to respond, 30 days for the first meeting).  Based on our public comment regarding the Waiver Regulations, we were told the manuals would provide information on requesting exceptions; however, the manual does not provide this information.  How do we proceed to request an extended timeline when 25 more slots are being assigned at one time?

CommentID: 116624