Virginia Regulatory Town Hall
Department of Medical Assistance Services
Board of Medical Assistance Services
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3/10/23  12:01 pm
Commenter: Kelly Ligon

Public Comment

Consumer choice is essential for individuals with disabilities so that they can determine who cares for their needs and supports their desires and rights as a person. 

Requiring legally responsible adults to become employs of an agency:

1) strips waiver participants of the right to choose participant directed services, and removing this right is based solely on the participants disability and extraordinary care needs that result in the need for a legally responsible adult to provide care

2) places an undo hardship on caregivers who are already caring for their individuals 24 hours a day, 7 days a week.  These caregivers have already been identified as the most qualified individuals to care for the consumer with a disability, already have the training from years of caregiving, and can identify nobody else to provide the care that they are providing on a daily basis.  They are unable to leave their individuals to attend training or testing for certification and likely will not able to meet these requirements solely due to their existing caregiving responsibilities - because the very nature of this service means there is nobody else to provide this care.  

3)  Agencies are already understaffed and cannot meet the needs of existing clients.  They do not have staff to train, certify and supervise an influx of new parent/spouse providers.  There are no increases in the budget to support this increase in staffing demand for agencies.  

Please renew Family and Individual Supports (FIS) and Building Independence (BI) 1915(c) Home and Community-Based Services Waivers to the U.S. Centers for Medicare and Medicaid Services to protect the rights of individuals with disabilities.

CommentID: 211371