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Virginia Regulatory Town Hall
Department of Medical Assistance Services
Board of Medical Assistance Services
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11/4/21  6:21 pm
Commenter: Michelle Lotrecchiano, MVLE Inc.

Comments - Therapeutic Consultation

• People with a BI waiver need access to therapeutic consultation, “professional consultation to assist individuals, parents, guardians, family members, and any other providers of support services with implementing the ISP.” This service provides expert consultation to the entire support system that enables them to achieve outcomes in the ISP without the expense of ongoing therapy services. o DMAS is aware of significant and systemic barriers to accessing technology that individuals need to interact with their providers and greater community. TC providers are specifically and uniquely qualified to provide assistive technology and medical equipment assessments, recommendations, training, and follow-up adaptations in accordance with the manual and the regulations, “provides assessments, development of a therapeutic consultation support plan, and teaching in any of these designated specialty areas to assist family members, caregivers, and other providers in supporting the individual.” Increasing access to TC to more people for AT assessment and facilitation would alleviate these barriers for individuals who don’t know how to engage and participate in the virtual environment, including telemedicine with healthcare providers. o TC offers an opportunity for provider choice from multiple disciplines and is one of the few regulated and reimbursable services that can be delivered effectively from a safe distance via telehealth and telephonic consultation. Individuals and families want more control over the services they receive and how they receive them. Access to consultation with an expert in any discipline of therapy would demonstrate to advocates Virginia’s commitment to the principles of the DOJ settlement, which includes all HCBS waiver recipients. o All individuals, regardless of which waiver they have, is experiencing the detrimental impacts of uncontrollable environmental changes throughout our community, including support provider shortages, limited choice and control of care setting and service duration, and lack of workforce modernization resources for service providers. Individuals with a BI waiver are experiencing equally disruptive changes to the capabilities of their support system to implement their ISP as those with the FIS and CL waivers. • Pg. 142, “consultation provided by members of … disciplines that are designed to assist… with implementing the ISP,” mirrors the regulation at 12VAC30-122-550. However, because assistive technology professionals (ATPs) are not listed in the examples of disciplines that can provide TC, DMAS will not enroll them as providers. This is a wasted opportunity. The Rehabilitation Engineering and Assistive Technology Society of North America (RESNA) provides standardized credentialing for an ATP Certification, “The ATP certification recognizes demonstrated competence in analysing the needs of consumers with disabilities, assisting in the selection of appropriate assistive technology for the consumers' needs, and providing training in the use of the selected devices.” The TC manual and regulation provide allowable activities examples that include, “Assessing the individual's need for an assistive device for a modification or adjustment of an assistive device, or both, in the environment or service, including reviewing documentation and evaluating the efficacy of assistive devices and interventions identified in the therapeutic consultation plan.” The ATP discipline meets the regulatory requirement as a discipline, “designed to assist with implementing the ISP 12VAC30-122-550.” o Suggest adding “Assistive Technology Professional” to the list of example disciplines appropriate to provide TC services.

CommentID: 116643