8 comments
I suggest rewording the proposed definition of supported living on page 58. The proposed service description states that Supported living takes place in an apartment setting operated by a DBHDS-licensed provider.
This specificity of taking place ONLY in an apartment is restrictive and in fact conflicts with both the Licensing definition and the Waiver Manual definition. It may mislead Support Coordinators to not consider supported living options offered by providers in a licensed residential setting such as a condominium, an attached townhouse or detached house, since the Support Coordinators may not realize that services in these settings CAN in fact be authorized as supported living services.
Licensing regulations state that Supervised living residential service means the provision of significant direct supervision and community support services to individuals living in apartments or other residential settings. These services differ from supportive in-home service because the provider assumes responsibility for management of the physical environment of the residence, and staff supervision and monitoring are daily and available on a 24-hour basis.
The Waiver regulation 12VAC30-122-540 states that Supported living residential service shall take place in a residential setting operated by a DBHDS-licensed provider of supervised living residential service or supportive in- home service
I suggest guiding Support Coordinators on the distinction between group home (24 hour) and supported living is the scope and amount of services and to note that both services require the provider to include the physical residential setting while supportive services are distinguished because the individual provides their own housing and therefore the housing is not connected to the support services.
Within Chapter 12: Employment, Post- Secondary Opportunities, and Integrated Community Involvement> Employment Services under Waiver (page 124). The handbook indicates the following:
Ordinarily, DARS would be a first option for referral for employment services for people who use Waiver services. However, this may be bypassed when DARS has a waitlist. Acceptable documentation for this would be: 1) Written documentation from DARS or the school system, OR 2) Progress note that records the content of a communication that includes a name, date, and person contacted, documented either in the individual's file maintained by the SC on the ISP or the supported employment provider's supporting documentation. Unless the individual's circumstances change (for example, the individual is seeking a new job), the original verification may be forwarded into the current record or repeated on the supporting documentation.
The text needs clarification on the following:
As a provider, we want to ensure we continue to work with our Support Coordinators in properly utilizing the employment resources that are available to the individuals we support. Having clarity on what defines a DARS waitlist and where to access this information will ensure that Support Coordinators and providers understand expectations and help communicate informed choices to job seekers.
We, the Public Policy Committee of the Virginia Association for Behavior Analysis, have the following comments on the DBHDS DD Support Coordination (Case Management) Handbook.
On page 49, crisis prevention services staff should not revise the behavior plan as drafted. They should revise the CEPP, if indicated. Only the Behaviorist, who authored the behavior plan, should revise the plan.
On pages 97-98, consider inserting “Licensed Behavior Analyst and Licensed Assistant Behavior Analyst” under “Who else can help?” for Constipation, Dehydration, UTI, Change in Mental Status, and Elopement/Wandering.
On page 109, consider adding our association as a resource under Community Resources – www.virginiaaba.org.
We thank you for the opportunity to comment and welcome your continued partnership.
Current wording: Though it is not the responsibility of the SC to ensure that providers adhere to the additional requirements, it is important that SCs familiarize themselves with these requirements as they may need to discuss the settings with regulations with providers."
This is helpful but it stops short of conveying what is the "responsibility" of the SC for the HCBS. For example, what is the SC' responsibility for non-compliance outside of addressing with the provider.
Suggest: "Though it is not the responsibility of the SC to (enforce) provider's adherence to the additional requirements, it is within their responsibility to be familiar with the settings requirements as they may need to discuss the regulations with individuals they support and their families, as well as with providers. Support Coordinators should consult with the Community Resource Consultant for ongoing or repeated issues of non-compliance around the settings regulations."
"The Diagnostic Eligibility Review Form can be used to ensure that collected documentation substantiates a diagnosis that confirms eligibility for SC services."
Can the Department include a hyperlink to this form on this page/paragraph?
"For children through age 21 years of age, physicals must be completed according to the EPSDT frequency." Is there a chart for this frequency that can be hyperlinked here?
Page 39 (I think (page number is missing):
Should this section address the role of the CSB/SC when this form (Documentation of Individual Choice Between Institutional Care and HCBS) is either not returned to DBHDS or otherwise uploaded by the individual/family member into WaMS?