Agencies | Governor
Virginia Regulatory Town Hall
Agency
Department of Medical Assistance Services
 
Board
Board of Medical Assistance Services
 
Previous Comment     Next Comment     Back to List of Comments
11/4/21  8:28 pm
Commenter: Moms In Motion/At Home Your Way

Provider Input on DD Manual: Provider Participation Requirements Chp 2
 

Provider Participation Requirements

DD Manual Chapter 2

  • SF is listed at the beginning as a DD Waiver service, but seems to be the only service excluded from having its own section in this manual.  Why is that?  Please include Service(s) Facilitation comprehensively in the language of this manual

  • Manual pg 10, bullet 3 

    • “Providers must ensure that all employees or contractors without clinical licenses who will be responsible for medication administration demonstrate competency of this set of skills under direct observation prior to performing this task without direct supervision.”

      • PCA's under CD cannot administer meds.  Please clarify this point in this section of the manual so that it is not misinterpreted later

  • Manual pg. 9, last bullet

    • “In Accordance with 12VAC30-122-120 providers of services under any of the DD Waivers may not be parents or guardians of individuals enrolled in the waiver who are minor children, or in the case of an adult enrolled in the waiver, the adult individual's spouse. Payment will not be made for services furnished by other family members who are living under the same roof as the individual receiving services unless there is objective, written documentation, as defined in this subsection, as to why there are no other providers available to provide the care. Such other family members, if approved to provide services for the purpose of receiving Medicaid reimbursement, must meet the same provider requirements as all other licensed provider staff or consumer-directed employees. "Objective, written documentation" means documentation that demonstrates there are no persons available to provide supports to the individual other than the unpaid

      • Live In Attendants should be at the personal preference and/or of the individual/caregiver receiving services and should not be considered a last resort.  Individuals and their families have provider choice.  Provider choice should include who the CD Attendant is without having to jump through hoops.

  • Manual pg 7, bullet 1

    • “Support activities and support instructions that are inclusive of skill-building as may be required by the service provided and that are designed to assist in achieving the individual's desired outcomes;”

      • Support activities & instructions should NOT include skill building for PCA, Respite, and Companion under the CD model.  This needs to be clarified for CD Service providers.

  • Manual pg 7, last sub-section, bullet 3 

    • Examples of unacceptable person-centered progress note written documentation include:  •Notes that are not signed and dated by staff who deliver the service, with the date services were rendered; and

      • Please clarify/define this section requirements. Is this the CD-PCA notes/documentation or the SF?

  • Manual pg 7, bullet 3, sub-bullet 1

    • Follow the following documentation requirements:  Prepare and maintain unique person-centered progress note written documentation in each individual's record about the individual's responses to services and rendered supports and of specific circumstances that prevented provision of the scheduled service, should that occur. Such documentation should be written, signed, and dated on the day the described supports were provided. However, documentation that occurs after the date services were provided must be dated for the date the entry is recorded and the date of actual supports delivery is to be noted in the body of the note. In instances when the individual does not communicate through words, the provider must note his observations about the individual's condition and observable responses, if any, at the time of service delivery.

      • Please clarify/detail who needs to sign.  Additionally, this manual hasremoved language that appears in the regs (12VAC30-122-120, A, 12, e).  This manual should match the regs, and it should read, “Providers shall prepare and maintain unique person-centered written documentation in the form of progress notes or supports checklist as defined by the service.”

  • Manual pg 6, bullet 4

    • “Accept assignment of Medicare benefits for eligible Medicaid individuals;”

      • What does Medicare have to do with Medicaid waiver services?  This line does not appear in the regs (12VAC30-122-120) anywhere and needs to be removed from the DD Manual.

  • Manual pg 6, bullet 6

    • Maintain and retain business records (e.g., licensing or certification records as appropriate) and professional records (e.g., staff training and criminal record check documentation). All providers, including services facilitation providers, must also document fully and accurately the nature, scope, and details of the services provided to support claims for reimbursement. Provider documentation that fails to fully and accurately document the nature, scope, and details of the services provided may be subject to recovery actions by DMAS or its designee.

      • Please clarify/define "nature, scope, and details" used in this section as it pertains to CDSF providers.  What exactly do CDSF providers need to document for this?  How and where should it be documented?

  • Manual pg 5, bullet 4-6

    • Why are these underlined?  Please explain these line items

    • “Accept training on Crisis Education and Prevention Plans (CEPPs) by DBHDS, or its contractor, based on individual needs.”

      • Clarify if this requirement will be mandatory for CD Service Facilitation providers.

        • Will this be a requirement to be done prior to seeing clients?

        • How will the CDSF provider be compensated for their time doing this?

        • How often is it required?  

  • Manual pg 4, sub-bullet 1

    • In order to ensure compliance with CMS requirements as well as protect the privacy of those who are providing services to individuals enrolled and receiving services through the Developmental Disabilities Waivers during Quality Management Reviews, the provider must retain the following documentation and make it available upon request:

  • Verification that fingerprints were obtained and sent (copy of what was sent to include a date)

  • Verification that the results were received (letter from company indicating the results)

  • Verification, if there was evidence of a conviction, that the results were reviewed and there is a statement indicating the results were reviewed to determine if barrier crimes were or were not noted. The statement should be signed and dated with the printed name and title included)

  • Fingerprint requirements are not mentioned in the regulations (12VAC30-122-120, A, 15) for CDSF Providers.  CDSF providers should not have to do this for their employees/staff.  This statement needs further clarification to omit CDSF providers from this requirement.

  • Manual pg 3, bullet 2

    • “Perform criminal history record checks for barrier crimes in accordance with applicable licensure requirements at §§ 37.2-416, 37.2-506, and 37.2-600 37.2-607 of the Code of Virginia, as applicable. If the individual enrolled in the waiver is a minor child, also perform a search of the VDSS Child Protective Services Central Registry. The provider will not be compensated for services provided to the individual enrolled in the waiver effective on the date and afterwards that any of these records checks verifies that the staff person providing services was ineligible to do so pursuant to the applicable statute.”

      • Please detail how often providers are required to perform these background checks on employees.

        • Please detail which specific “providers”.

        • We are a CDSF provider, what is the requirement for our field of expertise?

          • Denoting “providers” in the manual makes a general statement that all providers are held to licensure requirements.

          • CDSFs are not licensed; this requirement should state that it does not apply to certain types of providers and list them out.

  • Manual pg 63, last bullet

    • SELF-DIRECTED AND AGENCY-DIRECTED OPTIONS:  Perform criminal history record checks for barrier crimes in accordance with applicable licensure requirements at §§ 37.2-416, 37.2-506, and 37.2-600 37.2-607 of the Code of Virginia, as applicable. If the individual enrolled in the waiver is a minor child, also perform a search of the VDSS Child Protective Services Central Registry. The provider will not be compensated for services provided to the individual enrolled in the waiver effective on the date and afterwards that any of these records checks verifies that the staff person providing services was ineligible to do so pursuant to the applicable statute.

      • Please clarify/define how often each specific provider should/must conduct criminal record checks.

      • What is the purpose of the underlining of the last sentence in this section?

 

CommentID: 116663