On behalf of the Chesterfield Community Services Board, thank you for the opportunity to comment upon the intentions of DMAS to publish Omnibus Waiver Regulations.

While appreciating the effort to streamline regulations and find efficiencies wherever possible, Chesterfield CSB strongly believes that the MR Waiver and MR Day Support Waiver regulations should remain entirely separate beginning with 12 VAC 30-120-211 through 12 VAC 30-120-249 and 12 VAC 30-120-1500 through 12 VAC 30-120-1550.

These two MR Waivers have evolved with significant unique features that respond to the special circumstances in Virginia and the population being served.  Managing these MR Waivers without respect to those unique features will create a significant risk to the population that is targeted for services.  Among the most important unique features are:

• The assessment process and instruments, preauthorization process and authority, and the overall management of the significant waiting lists are accomplished through cooperative agency activities
• The role of the CSB case managers in managing both the waiver access and the needs of consumers in conjunction with state agencies
• The unique shared authority of the DMHMRSAS and DMAS in the oversight of the MR Waivers
• The historical understanding of the state leaders concerning the value of the MR Waiver and its use as a benchmark for state support for that population

Essentially unlike other Waiver tools, the MR Waivers have been developed over time to be managed in a manner that best meets the needs of the families and consumers who relate to their individual local CSB.  To do that, it required teamwork and coordination among state and local agencies.

It is the concern of all involved, the CSB board, service staff, consumers and families that it has taken time and effort to create a system to effectively manage the distribution and use of the MR Waivers.  We respectfully request that the existing sytem be respected and maintained.

Sincerely

George Braunstein