Good Morning,

My name is Marietta Cottingham. I am one of the Assistant Executive Directors of Serenity C&C, Inc. in Tidewater, and Central Virginia. Our company provides Sponsored Residential Support to approximately one hundred-ten adults and children   We also provide Day Support to approximately 25 individuals, Community Engagement to about 45 individuals, Out of Home Crisis Intervention, Children’s Respite Services and Applied Behavior Analysis (25 children). 

We have approximately 100 contractors and 75 staff.

This morning I want to comment briefly to tell you what I see as a problem with the Proposed Customized Rates and the effects they will have on Sponsored Residential Support Providers and the individuals they support 24 hours daily, seven days a week.  This proposal is prejudicial and counterproductive. It exacerbates the current shortages of available Direct Support Professionals.

In Section 7.2 of the Guidance Document for the Public Comment Forum the reader will find five bullet points relating to pay for staff needed to provide the additional care and support for some persons receiving support in Sponsored Residential Homes.

Taken together the five points seem to have been devised to make sure no Sponsored Residential Provider would benefit financially from the customized rate rather than to assure that appropriate support and care would be available to ensure the health and safety of the person receiving services with exceptional needs.

The five points are focused much more on disqualifying persons who reside in the Sponsored Residential Home than on making the best possible support available.  The spouse, child, sibling or other acquaintance of the Sponsored Provider, living in the home, cannot be hired to provide customized support regardless of that person’s qualifications, ability, willingness or desire to do so.  But someone else who might have less qualifications, experience, and awareness of the wants and needs of the person receiving services can be hired.  A situation like this might not happen often but it does not need to be possible at all.

An adult child or spouse of a sponsored provider might have a long-standing empathetic friendship with the person receiving services.  The adult child or spouse may be fully qualified and trained and experienced in all the aspects of providing residential support.   The adult child or spouse may be the person most preferred by the person receiving services.  If this adult child or spouse lives in the residential home, he or she cannot be hired to provide additional support. But if this same person lives elsewhere, he or she can be hired.  Why is this prejudicial restriction applied to this situation?  Are we not always told to provide the best support available?  Are we not expected to honor the individual’s choice of support provider?

Finally, this is a time when it is almost impossible to hire and retain proficient Direct Support Professionals.  There is a major shortage of people to provide this essential service, yet we have here a proposal to exclude many persons who have the desire, the ability, the experience, and the potential to provide exceptional support to persons who need and have the right to excellent support.  These proposals have the potential to seriously jeopardize the health and safety of individuals with the greatest needs.

Remove the biased restrictions that are included in section 7.2 of the Proposed Customized Rate.

Thank you the opportunity to express my concern.