Bullet 9, which carries into the next page is more restrictive than the regulations, which do not stipulate that an individual MUST try to find an attendant first that lives outside of the home before hiring someone that lives "under the same roof". https://law.lis.virginia.gov/admincode/title12/agency30/chapter122/section460/ section C is where the regs talk about who can and cannot be a PCA and nowhere in the regs does it say that the PCA cannot live under the same roof. The regs do not even mention the words "Objective Documentation" anywhere. My opinion is that this bullet in the manual should be removed or language that matches the regs should be used in its place, such as Section C-9 in the regs.
Page 7:
AT Only (T1999) is missing the 30% markup for providers.
Page 9:
Paragraph 2 following the bullets, "Therefore, services that do not involve directly support the individual or environmental services dealing exclusively with an individual's surroundings rather than the individual are not covered." This language does not appear anywhere in the regulations: https://law.lis.virginia.gov/admincode/title12/agency30/chapter122/section270/ - section C. This is an interpretation by DMAS that is not supported by regs and is more restrictive than the regs.
Page 18, Companion Services:
"Documentation submitted with the service authorization request must confirm that the service is not purely recreational in nature." What does that even mean? How is that defined? I have the same comment for Page 19 under CD Companion Services, paragraph 3.
Page 20:
Paragraphs 2 and 3 are redundant
Page 52:
CD Respite, paragraph 2, typo in the sentence, "...reminders to take self-administered medication or other medical needs, or monitoring OR her health status or physical condition." The word "OR" should probably be "OF".
General comment:
While Service Facilitation does not require service authorization under the DD Waivers, it is a listed FIS/CL Waiver Service (12vac30-122-500. Services facilitation service) (https://law.lis.virginia.gov/admincode/title12/agency30/chapter122/section500/) in the regs and should be listed in the section of this Appendix where all other Waiver Services are listed. It is mentioned in the CD sections of this appendix, but it is not specifically listed as its own waiver service, and it should. We have billable codes just like every other service on these waivers. This manual should spell out who can and cannot be an SF, when it's appropriate to engage an SF (CD services only, for example), and what the minimum requirements (educational/professional/administrative) the "...unpaid person (such as a family member) acts in this capacity" should have in order to provide SF services, etc.
