To Whom It May Concern,

At Home Your Way/Moms In Motion would like to thank you in advance for your time as you review and consider the following comments in the final text of this regulation. We are providing comment on the proposed text changes to Long Term Services and Supports Screening. As services facilitation providers that have guided people with disabilities and their families through the screening process for long term services and supports for seven years we have noticed over the last two years that there have been trending changes in the number of people with disabilities who are approved. Among the trends, we are most concerned about the steep decline in approvals for children with varying disabilities but most significantly children with Autism that despite their age and disability are denied even when they meet the functional, financial and medical nursing criteria.

It is unclear where the discrepancies in screening lie and we are therefore supportive of the establishment of training requirements set forth in this proposed text. December 2018 is over a year away, we encourage review of denials by the Department of Medical Assistance Services (DMAS) to establish a foundation for needs assessment and planning to address the significant trends and make public data regarding the number of people who are referred to screening, request screening, are approved, denied, appeal, and their ages. Furthermore, we encourage training for screeners that includes both adult and child screening as the criteria for eligibility and processes differ greatly (12VAC30-60-310. Competency training and testing requirements). We have reviewed the November 22nd Medicaid Provider Manual Update/Revision regarding child screenings and believe that the 0-5 criteria considering the child and parent as a unit may further limit eligibility when screeners interpret the criteria without consideration of “other complex medical needs or equipment” to complete the Activity of Daily Living task. It has been our experience that various DMAS contracted screening locations vary greatly in interpretation of screening guiding documents and therefore the number of people approved or denied. The inconsistency of interpretation for long term services and supports presents a barrier to access for people with disabilities and their families.

Additionally, we often receive reports of over the phone denials of requests for screening and a lack of written notice when screening is denied leading to the absence of determination notice and right to appeal. The regulations do not indicate, nor should it be included, that screening should be conducted or eligibility determined over the phone.

Finally, we recommend that appropriated designees for adult referrals for screening include “an interested party having knowledge of an adult who may need LTSS” (12VAC30-60-304). This is similar to the designated referral entities for children wherein community members who have identified a need may initiate a referral. It would therefore support the health and safety of adults who are aging or impacted by disabilities in the community who may be isolated, declining in competence, passive in behavior, or simply unaware of available supports and services.

Sincerely,

Jessica “Flip” Grey, BSW

Compliance Analyst and Advocate

At Home Your Way/Moms In Motion

Flip.Grey@MomsInMotion.Net

1(800)417-0908