DD Waiver Manual Comments; 

Nursing Service Authorization Period (Skilled Nursing and Private Duty Nursing Services): It is requested that the outline of a six month period of authorization be revised to reflect the plan year referenced within the regulations. Nursing services are truly vital for many individuals and this additional requirement again places additional burden upon agencies who are working to provide these services. The medical community is strained in a manner where it is proving to be increasingly difficult to obtain the needed documentation to support a service authorization request for a full year, with physicians increasingly declining to sign documentation. If this was then required every 6 months, the medical community may not be open to fulfilling this need, which would result in the decrease in these services for individuals who require nursing services in order to maintain a quality, healthy, and safe life within the community. Please revise this to align with the regulations currently in place to continue to support these service options for individuals within the state. 

Group Home Residential Services: There is reference within the manual related to a need for the fourth quarter review to include an annual summary. This is an additional requirement that is not outlined within our services within waiver nor outlined within regulations. This wording should be removed. 

Thank you in advance for your review and for working to make needed changes as recommended within the various comments pertaining to this draft manual.