Virginia Regulatory Town Hall
Department of Behavioral Health and Developmental Services
State Board of Behavioral Health and Developmental Services
Guidance Document Change: Support Coordination/Case Management is the core service that Virginians with developmental disabilities and behavioral health disorders use to help navigate and make the best use of Virginia’s publicly funded system of services. Strengthening the Support Coordinator’s/Case Manager’s role is essential to assuring effective and accountable services within the Medicaid Developmental Disability Waivers. The purpose of this manual is to guide Support Coordinators in all aspects of their work. These adjustments include altering wording for clarity, reorganizing content for easier navigation, providing language updates that are in line with current support coordination practices, and condensing portions of chapters for clarity and conciseness. The draft can be viewed here:
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1/17/24  3:57 pm
Commenter: LaVoyce Reid

Comments on Chapter 1 and 2
Comment #1: Chapter 2 (Support Coordination Overview) – The manual uses a definition for ID as defined by the American Association of Intellectual and Developmental Disabilities (AAIDD), for which I have no objection. However, I assume all of the CSBs/RBHAs define ID according to the code of Virginia and this is not mentioned in the section on ID Support Coordination. An important difference: it’s not sufficient to just know the individual’s IQ (as suggested by the AAIDD definition), but this needs to be based on a qualifying standardize measure for intellectual functioning (as conveyed in the state’s definition). Simply put, our eligibility determinations are based on the Code’s definition and not AAIDD, so I don’t follow why this section (on ID SC) doesn’t mention the Code’s definition for ID. The wording suggests that the AAIDD definition should outweigh what the Code defines (and how it defines ID). BTW, Page 18/section on “Support Coordination for people with DD begins” defines DD according to the Code of Virginia. Comment #2: Page 20 (top) The four (4) bullet points repeatedly refer to the individual as “recipient” and this is no more a person-centered term than client or consumer. Would suggest some re-wording of this section so that it is more person-centered: For example: • Instead of “A person who is a recipient of the DD Waiver” use “A person that has a DD Waiver.” • Instead of “A person with ID on the waiting list for the DD waiver who is eligible for Medicaid (in this instance the person may or may not be a recipient of one of the Waivers”) Use “A person with . . . (in this instance the person may or may not have one of the waivers). • Instead of: A person with a DD (diagnosis) on the waiting list . . . . (in this instance the person may or may not be a recipient of one of the Waivers) | Use “A person with . . . (in this instance the person may or may not have one of the waivers). • Ditto above: (in this instance the person may or may not be a recipient of one of the Waivers) | Use “A person with . . . (in this instance the person may or may not have one of the waivers). Comment #3: Same section (top of page 20 4th bullet point) – These bullet points are about eligibility for TCM (State plan option). Bullet point #2 is about someone with ID on the waiting list and bullet point #3 is about someone with Dd on the waiting list. (Bullet 1 is someone with a DD Waiver). Bullet #4 is about someone with “ID” that is “not” on the waiting list and is eligible for Targeted Case Management. Question: What about someone with “DD” (other than ID) that is “not on the waiting list. Comment #4: Page 20 (middle of page/Post Move Monitoring) – Since there’s just one Training Center remaining, could they simply refer to Southeastern Virginia Training Center (throughout the document) than wording that suggests multiple or more than one TC? Comment #5: Page 23 – continued SDM/ADMA(agreements) – this section uses the terms supportive and substitute interchangeable. Would suggest using Supportive and if use of the term “Substitute” is used intentionally (for example, in reference to a legal guardian, specifically) then perhaps this can be more clearly written. Comment #6: Virginia’s continuum of Decision-Making Supports |It’s helpful that the document defines each of these areas ((e.g., SDMA, Advance Directives, POAs, Authorized Reps, Temp guardianship and limited guardianship, and full guardianship). Consider examples of when to consider or suggest one versus the other.(e.g., an individual with multiple exception medical needs may do better with a guardian that has either limited or full authority versus a SDM.) Comment #7: Page 24 second paragraph from the bottom. Suggest using “individual” instead of “loved one.” Comment #8: Page 24 (bottom / 2nd bullet point) This line reads, “The LG ultimately makes all decisions that are made regarding the care of the “incapacitated person.” Actually, I think this should read, “The LG makes decisions that are pursuant to the guardianship court order for the “incapacitated person.” Comment #9: Page 25 / Appeals Rights (second paragraph). A SC may need to assist a person to request an eligibility appeal in writing within 30 days of receipt of the notice about the action. The person may write a letter or complete an Appeal Request Form that would include: . . .” Clarification: Is “The Person” here considered the SC or the individual? (we have, for example, permitted SCs to assist with this, as needed; however, we caution against them actually writing such letters just in case something is done wrong (I don’t want to risk an appeal being accepted or denied because of something in or not in the letter.)
CommentID: 221110