The Arc of Virginia appreciates the opportunity to review and comment on the Draft Telehealth Services Provider Manual Supplement. 

Due to the difficulties that people with Intellectual and other Developmental Disabilities face, the implementation of an effective and accessible Telehealth system is essential for Virginians.  

The Arc of Virginia supports the disAbility Law Center of Virginia's comments to combat the barriers that people with IDD encounter when trying to obtain healthcare.  

People with Medicaid Waivers are at very high risk of hospitalization.  Accessing telehealth has the potential of reducing health care costs and most importantly better health outcomes.  There are several areas in the draft that raise questions and additional clarification would be helpful.  They are:
Why is Remote Patient Monitoring limited to people who have at least 2 or more hospitalizations or Emergency Dept. visits?

Are people who live in licensed HCBS residential homes/facilities excluded from using telehealth if the residence is the originating site?

Will Medicaid regulations and authorization requirements allow people to access funding for technology and equipment necessary for HCBS users to access telehealth? 

Thank you for considering these comments.