COMMENTS ON ASSISTIVE TECHNOLOGY (AT) IN THE DD WAIVER MANUAL CHAPTER IV
General Comment: Assistive Technology (AT) is an HCBS waiver benefit that all recipients of DD waivers and CCC+ waivers are equally entitled to access in accordance with regulations at 12VAC30-122-270. Although there is only one regulation for AT, guidance for administration of it is inconsistent. AT requests for people with a DD waiver are approved by DBHDS according to the DD Waiver Manual Chapter IV and AT requests for people with the CCC+ waiver are approved by the MCO or KePRO according to the Durable Medical Equipment (DME) and Supplies Manual Chapter IV. Review of both manuals find extensive differences and variations, and both manuals are more restrictive than the AT regulations they are purported to clarify.
These contradictions and inconsistencies represent the root causes of many of the barriers individuals, providers, and DMAS are experiencing as reported by the HB2197 working group that DMAS was charged with hosting to identify barriers to accessing AT and related services as well as options for removing them. Making the administrative manual changes recommended below will remove many of these barriers that impact over 30,000 people with disabilities. Only the DD Waiver Manual is open for public comment; the DME Manual was closed in June 2021 after receiving zero comments. We strongly urge DMAS to revise both Manuals to appropriately reflect the AT regulations at 12VAC30-122-270 in order to remove many systemic barriers to assistive technology access. Suggested revisions for both manuals are provided below.
DD Waivers Manual, IV, Assistive Technology
Durable Medical Equipment and Supplies Manual, IV
Suggested Revisions for the section that begins with, “The following conditions,” through the end of the AT section on p28 to comply withAT regulations (12VAC30-122-270):
“The following conditions must be met for DMAS to approve reimbursement of assistive technology equipment. These conditions are applicable whether the equipment is for initial use or replacement. Individual use of the requested AT will enable increased abilities to:(at least one)
For each assistive technology request for approval, the AT provider or the independent professional shall provide documentation of:
In order for an AT claim to be reimbursed, all of the following must be documented: