Virginia Regulatory Town Hall
Department of Medical Assistance Services
Board of Medical Assistance Services
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3/27/23  9:03 pm
Commenter: Karen Tefelski, VaACCSES

Disparity for Children with Disabilities - EPSDT AT

Pg. 90 of 333, “In accordance with the CMS Informational Bulletin issued on July 7, 2014, assistive technology for individuals under age 21 shall be accessed through the state plan pursuant to EPSDT. Assistive technology through this waiver shall not be available to individuals under age 21.”

The EPSDT criteria are stricter than the waiver AT service criteria, creating an inherent disparity in access to AT for disabled children compared to equivalently disabled adults. Children requesting AT to enable their abilities to participate in ADLs, to perceive, control, or communicate with their environment, or to actively participate in other waiver services that are part of their plan for supports are denied if the AT item does not alleviate the effects of, or maintain their diagnosis from worsening, while adults with the same disability and the same requested AT item would be approved. Most personal care and hygiene items that enable the individual to autonomously clean themselves or feed themselves are only accessible to those waiver recipients 21 years old or older because they do not meet the EPSDT criteria.

Please allow children with an HCBS waiver to access the waiver AT service, which they are eligible to receive, and funds have been allocated to, if their request does not meet the stricter EPSDT AT criteria.

CommentID: 214194