I support John Malone of the Harrisonburg Rockingham CSB and other CSB commenters in their concerns and recommendations.

I share the concerns in the 3/27/19 post of Groff – Bedford adult day care; however, feel the recommendation is extremely unwise as it would inadvertently have a significant impact on a large number of individuals served who do not have these medical issues, unfairly impact supervisory individuals who have achieved the functional equivalency status through multiple years of demonstrating dedication and all of the required knowledge, skills and abilities necessary to perform the supervisory function well – rather the state should include the functional equivalency acceptance in the definition of QDDP and/or grandfather in current functional equivalents the way they did with CSB’s and moved to a higher standard going forward.

On the comment regarding the day as the sole unit for residential reimbursement, one colleague suggested that a possible reason for the current approach was because some residential providers may encourage individuals not to engage in employment or outside day support for additional reimbursement and this runs counter to the State’s goal of increasing involvement in employment/outside day supports. Preemptively, because the state does not provide an opportunity for rejoinder it’s important to point out that these issues should not be considered an answer to the criticisms nor adequate rationale for continuing the current system: 1st – the financial incentive for residential providers to encourage individuals to not attend an outside day program is greatly reduced when compared to the existing financial incentive to push them out the door, because the residential provider would have to provide staff and supports during the time the individual is there; whereas now a residential provider collects the money with no offsetting cost; 2nd – periodic supports are not suggested in the recommendations and if no periodic support reimbursement or available residential providers would have no incentive to encourage individuals to remain home on a given day if they were enrolled in an outside program; 3rd – solely residential providers could not prevent individuals from signing up for a day program outside the home is this is a decision made between the individual and the support coordinator – once the individual indicated to the support coordinator they desired a day placement it can be set up and arranged independent of the wishes of the residential provider; 4th – a better system of checks and balances would be in place to prevent the rights abuses which are occurring now, as the day support staff would have an incentive to have the individual attend day support (and thus protect their jobs) which could serve as a counterweight to any financial incentive for the solely residential provider; 5th – the State’s goal of increasing involvement in employment/outside day support should not be accomplished through abuse of individual CMS final rule rights, no matter how laudable the state may feel these goals are state abuse of individual rights should not be permitted in their pursuit.