I would like to express my strong support for the comments submitted by Chimes regarding the proposed amendments to Virginia’s 1915(c) Home and Community-Based Services Medicaid Waivers.

Having worked extensively in services supporting individuals with intellectual and developmental disabilities, I understand how critical Medicaid waiver services are to maintaining the health, safety, independence, and quality of life of the individuals who rely on them.

I share Chimes’ concerns regarding proposed changes 7 and 8, particularly the removal of higher-level reviews by DMAS when an individual is determined to no longer meet waiver eligibility requirements, as well as changes to the role of managed care organizations in service plan quality reviews. These oversight processes serve as important safeguards against inappropriate reductions in services and potentially erroneous determinations that could jeopardize an individual's continued access to essential supports.

For individuals with significant support needs, even a temporary disruption in services can have serious consequences. Families and providers are already navigating complex regulatory requirements, workforce shortages, and funding challenges. Removing existing oversight mechanisms without clearly established and equally effective protections creates unnecessary risks for an already vulnerable population.

While administrative efficiency is important, it should never come at the expense of accountability, due process, or the well-being of individuals receiving services. Any proposed changes should include clearly defined review procedures, meaningful opportunities to challenge adverse determinations, and safeguards to prevent unnecessary disruptions in care.

I strongly encourage DMAS to reconsider these proposed amendments, maintain appropriate levels of independent oversight, and engage individuals receiving services, families, advocates, and providers before implementing changes that could significantly affect access to care.

I fully support Chimes’ recommendation to delay implementation until DMAS can demonstrate that adequate protections are in place. Individuals with disabilities deserve a system that prioritizes their rights, safety, dignity, and continued access to the services that allow them to live meaningful lives in their communities.