Chimes welcomes the opportunity to submit comments to the proposed 1915(c) Home and Community-Based Services Waivers Amendments. We appreciate efforts to ensure quality of care in Virginia’s home and community-based services and ask DMAS to reconsider the timeline and implementation of the proposed changes.

Chimes and its affiliates assist individuals throughout the mid-Atlantic region with intellectual and developmental disabilities (I/DD) achieve their fullest potential. The vast majority of our clients utilize Medicaid funding to support their care needs. Throughout Virginia, Chimes proudly operates ten residential homes and one day program. The organization employs 100 staff who support nearly 100 individuals with I/DD in Northern Virginia.

Federal changes to the Medicaid system as a result of the One Big Beautiful Bill Act (OBBBA) sought to create a system that not only restricts access to care for vulnerable populations but places an unnecessary administrative burden on providers and state Medicaid systems. The proposed changes to the HCBS waiver system would amplify this by removing current review safeguards without an effective and efficient replacement. Implementation of the proposed changes on a short timeline leaves little allowance for changes to be made by families and providers to ensure there is no lapse in care for individuals with disabilities. Chimes has significant concerns about the proposed changes, especially changes 7 and 8.

• Removing the requirement that DMAS staff perform higher level reviews when the individual is found to no longer to meet the level of care to remain on the waiver (CCC+; Appendix B-6)
• Updating service plan quality measures to remove the managed care organizations from performing the review (CCC+; Appendix D Quality Improvement)

Individuals with I/DD are already seeing significant reductions in care hours which has a direct impact on their safety and quality of life. Removal of the higher level of review along with the overall remove MCO’s from performing reviews will only increase these reductions as waivers are denied without proper review. Individuals with I/DD, their families, and providers are then left to determine how to provide services with a lack of funding to support it. The proposed changes will also cause additional administrative burden across the system as individuals and providers seek to appeal waiver denials.

Chimes urges the DMAS to maintain the current level of review and delay implementation of further changes until safeguards and assurance can be provided that changes will not result in additional reductions in care and denials. DMAS must prioritize the care and well-being of individuals with disabilities above all else and ensure that everyone has access to the care they deserve. Additional levels of review provide protections against erroneous disenrollment.

Chimes and our affiliate Chimes Virginia appreciate the opportunity to provide comment and welcome questions about the harmful impact of the proposed changes.