Virginia Regulatory Town Hall
Department of Medical Assistance Services
Board of Medical Assistance Services
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10/28/21  7:26 am
Commenter: Holly Rhodenhizer, enCircle

DD Waiver Comments


  1. Chapter 2 Comments:
    1. Referring to the Minimum Elements of Person-Centered ISP
      1. Comment: is this the responsibility of the Support Coordinator or the Private Provider
  2. Chapter 4 Comments:
    1. Skilled Nursing (SN) service means nursing services that are provided by a Registered Nurse (RN) or Licensed Practical Nurse (LPN) in the form of intermittent care, up to, but not to exceed 21 hours per week as detailed in the individual’s ISP.
      1. Comment: While this isn’t common, we could have a short-term situation that may support 21+ hours a week to maintain the least restrictive environment. Please consider allowing this for short term situations.
    2. Skilled Nursing - Documentation of the Physician or Nurse Practitioner orders must be completed every six months. This means that the CMS 485 and the individual plan for supports related to SN services must be updated every six months.
      1. Comment: This process is already very tedious, and we have ongoing challenges with receiving orders from Physicians and Nurse Practitioners in a timely manner. Our nurses spend significant time calling and faxing physicians. Changing this to every six months creates an even greater burden on an already overworked and underfunded nursing workforce.
    3. The annual updates to the plan for supports and every time supporting documentation is updated, the update must be reviewed with the individual and family member/caregiver, as appropriate, and such review must be documented, either by the individual and family member/caregiver's signature on the review, or a progress note describing the discussion.
      1. Comment: Can you please clarify what “supporting documentation” is?
    4. All Services: The content of each review must be discussed/reviewed with the individual and family member/caregiver, as applicable and submitted to the Support Coordinator within 10 calendar days following the end of each quarter. The discussion must be documented either by the individual and family member/caregiver's signature on the review or a progress note describing the discussion.
      1. Comment: Participation and signatures can be challenging to capture. This process has potential to delay the ten-day due date. Could we please have 30 days for the discussion/review to take place?
  3. Chapter 6 Comments:
    1. Documents cannot be signed electronically by anyone other than the individual required to sign the document
      1. Comment: Please clarify as we do have other persons involved sign the document
    2. There must be evidence that person-centered reviews for the waiver services are completed and sent to the support coordinator/case manager no more than 10 days following the end of each quarter as determined by the effective start date of Individual Support Plan. However, the original person-centered review due dates remain unaffected by the date the review is completed.
      1. Comment: Will uploading to WaMS suffice as evidence of timeliness or do we have to download a copy of this evidence to our electronic health record (EHR)? This consumes space in our EHR, and we would prefer to use WaMS as our evidence.
CommentID: 116575