12VAC30-122-120 -Provider requirements.

Providers of services under any of the DD Waivers shall not be parents or guardians of individuals enrolled in the waiver who are minor children, or the adult individual's spouse. Payment shall not be made for services furnished by other family members who are living under the same roof as the individual receiving services unless there is objective, written documentation, as defined in this subsection, as to why there are no other providers available to provide the care.

This should not be placed into regulation. As a mother of a child with a disability I think family members are the most critical resource to persons with disabilities. How awful of this team to restrict the support of a family member in the home, and for what purpose.  The family is often the most knowledgeable, concerned, and loving parties in this individual’s circle of support and who should care if the person lives in or out of the residence but the consumer being served. This should not be a political or even allowed by dollars that are used by the citizens of this state. You should have family member who has a disability and then ask yourself, “if you think a stranger would provide them better services than their grandmother, father, sister or brother”? I think not!

12VAC30-122-380. Group day service. -. Supervision of direct support staff shall be provided by a supervisor meeting the requirements of 12VAC35-105.

This standard is excessive and should not be put into regulation. Each Waiver provider currently performs monthly supervision with their staff that follows the expectations of their organizations policies. Adding the additional burden for waiver supervisors to complete the below mentioned task as a part of their monthly supervisory notes exceeds standards applicable to clinicians, administrative personnel, and all other health related services in DD, MH, and hospital systems.

Supervision is not just about the employee’s performance, but necessary supports, mentorship, professional development, employee needs, and other issues addressed by the supervisor or employee as needed. This requirement is too prescriptive and limits the purpose of the supervisory session and should not be put into regulation. Supervisor’s should be required to have records of their supervision that meets the standards of their organizations, and not be dictated to but any funder. A requirement to document on a monthly or semiannual basis to document is excessive (A- D) for this service

E. Semiannual documentation by the supervisor concerning the individual's satisfaction with service provision. - excessive as supervision is not about the individuals served but the employee who is being paid by the organization. Supervision should not be used as a satisfaction survey or instrument

12VAC30-122-320. Community engagement service - Service description.

A supervisor meeting the requirements of 12VAC35-105 shall provide supervision of direct support professional staff.

This standard is excessive and should not be put into regulation. Each Waiver provider currently performs monthly supervision with their staff that follows the expectations of their organizations policies. Adding the additional burden for waiver supervisors to complete the below mentioned task as a part of their monthly supervisory notes exceeds standards applicable to clinicians, administrative personnel, and all other health related services in DD, MH, and hospital systems.

Supervision is not just about the employee’s performance, but necessary supports, mentorship, professional development, employee needs, and other issues addressed by the supervisor or employee as needed. This requirement is too prescriptive and limits the purpose of the supervisory session and should not be put into regulation. Supervisor’s should be required to have records of their supervision that meets the standards of their organizations, and not be dictated to but any funder. A requirement to document monthly to document is excessive (A_D) for this service

E. Semiannual documentation by the supervisor concerning the individual's satisfaction with service provision. - excessive as supervision is not about the individuals served but the employee who is being paid by the organization. Supervision should not be used as a satisfaction survey or instrument.

Submitted by Cil Hurd - Burks