Please find the Moms In Motion and Ability Unlimited public comments:

Pg 44 of PDF (doc pg 1378) 12vac30-120-610 (A) 6:  

• Is HIPP now moving to CCC+ program?

Pg 46 of PDF (doc pg 1380) 12vac30-120-620 (A) 1, b:  

• The payment criteria should be the DMAS criteria, not criteria established by the MCO

Pg 46 of PDF (doc pg 1380) 12vac30-120-620 (A) 6

• This may contradict provider choice for the consumer

Pg 46 of PDF (doc pg 1380) 12vac30-120-620 (C)

• Our experience is that the MCOs are much more restrictive

Pg 46 of PDF (doc pg 1380) 12vac30-120-620 (D)

• Our experience is that the MCOs are not in compliance.  They deny IADL hours, they deny hours for bathing someone under 3 years old, etc.

Pg 46 of PDF (doc pg 1380) 12vac30-120-620 (E)

• Our experience is that the MCOs are not currently providing services in equal amount, duration, and scope.  They limit number of visits and number of MT units.  They also often partial pay for AT and EM services.  They are also cutting PCA hours, even when the dr. recommends higher on the DMAS-7.

General comment:

The appeal process through the MCO's is painfully long.  If, by some strange chance, the family actually enters their desire to appeal prior to their services ending, who is holding the MCO accountable for keeping their services going while the appeal is being processed?

We are finding that families are forfeiting the appeal process altogether because of its arduous nature and just using respite to pay their aides.  

We feel that someone from DMAS needs to be involved in the MCO appeal process to ensure that these at-risk individuals are not being put through an unnecessarily long appeal that ultimately denies them the services they've been receiving all along and that DMAS had previously approved.