This is contradictory.  The first sentence says the two visits are recommended, but not required and then the second sentence says after the first two routine in-hoe visits are done, a face to face must be done every 90 days.  So - now is only a visit at 30 days required?  It's confusing as to what the requirement is. 

 

Page 16 states that the SF must document whether or not the EOR is in the home at each visit.  

    Where is this to be done?  Will the 99 be modified to answer this question or are SFs expected to remember to put that in their notes?

 

Page 39 states:  If an individual is also receiving personal care services, the respite care routine visit may coincide with the personal care routine. However, the SF shall document review of respite care separately from the personal care documentation. For this purpose, the same individual record may be used with a separate section for respite care documentation. 

    What does this mean exactly?  Need clearer direction.  And, what is the purpose of this?

 

Page 94-95 address critical incidents and state: CRITICAL INCIDENTS   A critical incident is any incident that threatens or impacts the well-being of a waiver individual.  Critical incidents include, but are not limited to, the following:  • Medication Errors; • Severe Injury; • Falls; • Theft; • Suspected Mental or Physical Abuse, Neglect, or Exploitation; and • Death.  It is the responsibility of all providers, including aides and attendants, to report all suspected critical incidents as soon as possible.    For individuals in managed care, critical incident reports must be sent to the appropriate MCO using the MCO’s preferred method.  For incidents involving fee-for-service individuals, reports must be sent directly in an encrypted email to DMAS at FFS.CCCPSupport@dmas.virginia.gov.    When reporting a critical incident provide as much information as possible to include the individual’s name; Medicaid ID; date, time, and location of the critical incident and when it was first discovered; contact information of the individual, provider, and any witnesses who may also be able to give information; and a description of the incident.  If the incident involves abuse, neglect, or exploitation, APS or CPS must also be notified; see “Suspected Abuse or Neglect” for more information.  All providers are required to report critical incidents upon first knowledge of the incident. 

 

While the critical incident reporting requirements outlined on pages 94–95 are intended to ensure health and safety, the framing and implementation of these requirements reflect a predominantly medical model approach rather than a person-centered, consumer-directed philosophy. The policy positions individuals primarily as recipients of care whose well-being must be monitored and reported on by providers, rather than as autonomous individuals with the right to direct their own services and make informed choices about risk.

This approach may unintentionally undermine the principles of consumer direction by shifting authority and responsibility away from the individual and toward providers and systems. A truly person-centered framework would balance health and safety requirements with respect for individual autonomy, self-determination, and the right to assume reasonable risk. Without this balance, this requirement risks prioritizing compliance and surveillance over empowerment, which is inconsistent with the core values of independent living and consumer-directed services.