Valley Associates for Independent Living appreciates the opportunity to provide a brief comment on the FIS Waiver Renewal application.  First we stand with the Virginia Association of Centers for Independent Living in the 33 page document submitted for public comment.  In addition we offer the following comments:

Choice of providers for Case Management needs to remain a priority and option for families, including private Case Management entities that have a positive successful track record of providing these services.

Parents of minor-aged children and spouses who provide Medicaid-funded personal assistance should not be required to be hired under an agency.  There are many areas of the state that consumer direction is the ONLY option as home health agencies do not serve these areas.  Home health agencies, locally, have not stated that they are willing or have the capacity to hire parents and spouses to be paid attendants.  Taking away consumer direction as an option hinders families ability to receive care.  Home health agencies have historically not shared hours with consumer direction, meaning families would need to choose.  Several families have consumer direction with attendants hired, but due to the lack of attendants and the need of the individual it has become imperative that parents quit their jobs and become paid attendants.  If parents and spouses need to be hired by an agency, has DMAS confirmed and required that home health agencies share hours with consumer direction to ensure appropriate care?  Under the current situation if hired by home health they would then loose their consumer direction option for the other attendants.  Permit parents and spouses to remain attendants under consumer direction.  Appropriate safeguards are an option including nurse delegation as allowable under the code of Virginia, require an EOR that is not the other parent or spouse, etc.  It is imperative the Virginians maintain their choice of providers and that consumer direction remain a priority.