Thank you for the opportunity to comment on the proposed changes to Virginia's Medicaid waiver programs.

56-Hour “Soft Cap” for Personal Assistance

I strongly oppose the proposed changes to the 56-hour limit. My daughter has a rare seizure disorder, which occurs at any time of the day or night. She does not sleep through the night and has a profound cognitive disability. Her needs are complex.

Legally Responsible Individuals as Paid Aides/Attendants

I am also concerned about any changes involving the requirements for Legally Responsible Individuals (LRIs) who serve as paid aides or attendants.

Because of the significant caregiver shortage, I am filling the gap to provide care for my daughter and provide her with a safe home. 

The current and increasing requirements have become overwhelming and discouraging.

Removal of Higher-Level Review Following a LOCERI Finding That an Individual No Longer Meets Criteria

I oppose removing the requirement that DMAS staff perform higher level reviews when the individual is found no longer to meet the level of care to remain on the waiver. Because my daughter requires essential daily care, and I am a single parent, any mistake or incorrect determination can cause significant emotional and mental stress to me and other families. A reduction or termination of authorized hours can mean the inability for me to work outside of the home and maintain a home for us.

The higher-level review should be viewed as an important quality and accuracy safeguard, not simply as an administrative step that can be eliminated.

Electronic Visit Verification (EVV) for Live-In Caregivers

I am concerned about the planned elimination of the live-in caregiver exemption.

I provide continuous, unpredictable support that is intertwined with my other personal and family responsibilities.

My daughter has rare seizure disorder that cannot be completely controlled by medication. She needs one-on-care for all her Activities of Daily Living (ADLs)--elopement, behavior issues, toileting, medication needs, and other urgent circumstances in which I must immediately respond. Requiring me to interact with an EVV system during these times can negatively and seriously impact her level of care.