Thank you for the opportunity to allow for the review of this customized rate guidance document and the ability for comments to be made related to the content., for the very first time. The customized rate funding process has been in place for years and with each year there continues to be the addition of new requirements and stipulations that are put into place, which continues to limit the availability of this resource option for Providers.
The ability for Virginia to allow for an alternative process for funding rates is vital in supporting all individuals within services. The typical process of funding being tied to support needs as outlined within the SIS Assessment does not always capture more complex needs. The continued focus of the DOJ Settlement Agreement is on the need to have community options available for those individuals with significant behavioral and medical support needs. Providers truly want to support individuals across the state in varying support needs; however, the ability to fund services in an environment with limited staff and increased need for those staff who do come on board to have specialized skills and/or knowledge proves to be some of the many challenges.
At this time, the customized rate application process requires numerous hours and staff attention to gather, collect, organize, complete, and submit a number of documents to outline the support needs of each individual. The current process requires continued resubmission of documents at least annually for review and determination. If an individual is approved for customized rate funding this does not indicate any type of approval in subsequent renewal years in which the continued request can be denied.
There are now regulations related to customized rate funding; however, the information is limited in detail as compared to what is outlined within this guidance document. Typically, guidance documents are set forth to provide additional details as to a specific regulation or interpretation of regulations; however, this guidance document outlines key information not tied to an official regulation. With that said, it appears that the customized rate funding guidance document outlines more of the inability of additional funding to be approved, rather than the true intent of additional funding being authorized in order to support those individuals with the most intense support needs.
My recommendation to this guidance document is for the content to be reexamined and rewritten to function as a guidance document to current regulations and not as additional regulations. This would allow for a full review of this process with changes completed to allow for more ease in the completion and obtaining of these funds, which would allow Providers to be successful in support individuals of all needs throughout the Commonwealth.
Thank you in advance for your attention and review of these comments.