I have significant concerns about the role of Telehealth in service provision, including in these new services listed.

Telehealth promotes billing.  It allows for providers to eliminate travel time and to increase the number of billable activities and individuals seen in ALL models of service that allow for it.  That is not the same as supporting an individual in a service.  Telehealth for these services is counterintuitive to the individuals supported by the Waiver and further increases fraudulent supports, limitations on monitoring of services and the increase of abuse and exploitation in a field that is already rampant with it.

During the pandemic Telehealth was utilized to promote public safety but what was discovered were significant health and safety concerns that were either not visible to the Telehealth provider or not seen by the provider due to the limitations that a Telehealth option provides.  It is NOT SAFE for the individuals receiving CL Waiver to allow for Telehealth to replace necessary supports for in person services in any capacity.

These Telehealth options do not promote the benefits of the individuals in receipt of the Waiver.  Even in underserved areas, the focus should be on provider development in those localities, not the replacement of beneficial services and supports to Telehealth models.  The individual loses in this model as these service require direct hands on supports, not Telehealth options.

To address staffing gaps and limitations referenced as concerns via other public comments, it should be the obligation of DBHDS to provide pay related guidelines so that DSPs are provided livable wages and benefits like those in the CD model such as paid sick/annual leave and a state based standard wage rate.  As it stands now providers are allowed to set their own rates which creates agencies who do not provide comparable supports.  It is difficult for parents to navigate systems with rules that vary provider to provider without their awareness that this is in fact the case.

In addition, caseload limitations for support coordination could make this job manageable, eliminate staff turnover and help to promote the stability of services that have become significantly destabilized with the increases in oversight without protection to those doing the oversight.  Telehealth services for in-home, CE, CC, individual SE and workplace SE further increase the burden of monitoring for health and safety supports.  The same mandated reporter requirements were in place during COVID.  Health and safety concerns were missed because they were unseen during Telehealth service provisions, not because providers did not follow mandated reporter guidelines. 

Finally, DBHDS provides a requirement that support coordination “sign off” on Telehealth created options.  This creates a difficulty in service provision.  If a legal guardian has elected a service, where does the role of the service coordinator supersede that of the guardian?  A support coordinator can have concerns that are often overridden by SDMs.  While recommendations and concerns can be addressed and mandated reporter routes utilized, where will DBHDS stand when the guardian and support coordinator are at odds related to a service?  These guidelines do not provide any dispute resolution and do not resolve how to address potential fraud or service-related issues. I disagree with these suggestions. 

I will say I do like the very limited Telehealth options to enable a person to plan their CE or CC services on a very clear and limited basis for allotted activities.   That can make sense and be built into a plan while also ensuring that the supports are then done via in-person services.