First, I appreciate the clarification and further detail regarding service descriptions – currently there are different interpretations across providers, support coordinators and DBHDS/DMAS representatives (CRCs, PAs etc.) over service requirements.  This creates undue stress amongst an already strained industry and creates barriers for individual access to services. 

I have also reviewed and support the previously posted comments on this town hall.  A few points I would like to add (or stress.)

Page 112 (group day services)

"For group day services, an individual must demonstrate the need for skill-building or supports offered primarily in settings other than the individual's own residence that allows an opportunity for being a productive and contributing member of his community."  Further clarification is needed.  Who is to determine (and how) an individual's need for supports outside of their home.  It should be the individual's choice.  (The use of 'his' as an all encompassing pronoun is outdated.)

Page 153 (Group home)

"Each quarterly review will represent the quarterly data, however, the fourth quarter will provide an annual summary in addition to the fourth quarter data."  This is inconsistent with the standards for nearly every other service.  As each review represents the data for the quarter this would equal administrative redundancy.

Page 159-161 (In home)

"All individuals must have a backup plan prior to initiating services in cases of emergency or should the provider be unable to render services as needed..."  Currently, in home service authorizations are being pended in WaMS due to the 'back up plan.'  The inclusion of a back up plan is not included under "the provider's plan for supports."  Further clarification is needed regarding whose responsibility and where to note/upload the back up plan to WaMS.

Humbly submitted.