The Fairfax County Department of Family Services (DFS) appreciates the opportunity to provide comments on the proposed revisions to the LTSS Screening Manual. Our comments focus on the proposed changes to the Community-Based Screening Teams (CBTs) and the potential impact of these changes on service delivery, statutory compliance, and fiscal stability.

The current CBT structure is established by Virginia Code § 32.1-330(D), which mandates that the screening team:

"...shall be completed by a long-term services and supports screening team that includes a nurse, social worker or other assessor designated by the Department who is an employee of the Department of Health or the local department of social services and a physician who is employed or engaged by the Department of Health."

Based on our review, the revisions proposed on page 19 of the LTSS Screening Manual appear to be in direct opposition of this statute. By removing or making discretionary the role of the local department of social services (LDSS) assessor, the manual would bypass the multidisciplinary requirement of the General Assembly.

The LDSS Family Services Specialist (or equivalent) provides psychosocial assessments, navigation assistance, and service coordination. Removing this role from the CBT mandate raises questions regarding:

1. Who will be responsible for evaluating the social determinants of health and person-centered needs that fall outside the traditional clinical scope of a nurse or physician?
2. How will clients be transitioned from the screening process into the complex array of community-based services without the system-wide knowledge held by LDSS staff?
3. If the LDSS specialist is no longer a required member, what entity will perform the psychosocial and navigation components? 
4. How does DMAS interpret these proposed manual changes as consistent with the explicit requirements of Virginia Code § 32.1-330(D)?

The psychosocial components and transition planning provided by LDSS are essential to a stable, person-centered screening process. 

We offer these comments in the spirit of collaboration and remain committed to working with DMAS to maintain a legally compliant and effective LTSS screening process.