I have a number of recommendations which should improve the lives of those enrolled in the technology waiver and their caregivers. 

      First and foremost, if all those covered by the technology waiver have not received notification of these proposed rules and their ability to comment then they should be notified and the comment period extended for 30 days from their notification. 

      My specific comments below are predominately focused on four major concerns.  1) That the respite program be more accountable to and for the individual and that the hours be increased to 480 as in other waiver programs. 2) that there be provisions to make up missed hours of skilled PDN.  3) that there be a combined maximum of skilled PDN and PC of 20 hours per day. and 4) that AT be defined as equipment to meet specialized medical needs, perform ADLs and/or improve their function not necessarily be specialized medical equipment.  I am able to discuss in detail the rationale for each comment below but wanted to record all comments within the 3000 word limit.  My e-mail is eadkfreund@aol.com and phone is 571-332-2505

     Specific comments:

1 - Page 12, AT definition - Delete "specialized medical" from the first sentence.  Change "ADLs" to "ADLs and/or IADLs".

2 - Page 13, Congregate private duty respite definition - Change "240" to "480".

3 - Page 16, PC definition -  Change "ADLs" to "ADLs and/or IADLs".

4 - Page 18, Paragraph E - Change "...14 days ... authorized by DMAS and limited..." to "... 21 days per calendar year are allowed.  DMAS shall be notified of all such absences longer than 48 hours in duration.  These absences are limited..."

5 - Page 20, Paragraph 9 - Change second sentence to "The primary caregiver shall be responsible for all hours not provided by a RN or LPN, usually eight or more hours in each 24 period."

6 - Page 22, Paragraph 6d - Add "and scheduling of providers and services"

7 - Page 22, Paragraph 6e - Add "Be provided a monthly report of daily hours and services provided by type of hour and service and by provider.  If any hours or services are not in compliance, be provided an opportunity to correct the record.  The report shall be available by the 15th day of the following month."

8 - Page 23, Paragraph B - Add "PC for adults"  as a covered service.

9 - Page 23, Paragraph c - Add to the end "and where 16 scheduled PDN hours are not completed within a 24 hour period, the hours may be rescheduled and worked within the following 72 hours to support the primary caregiver."

10 - Page 24, Paragraph (6) - Add to the end "and where 16 scheduled PDN hours are not completed within a 24 hour period, the hours may be rescheduled and worked within the following 72 hours to support the primary caregiver."

11 - Page 25, Paragraph (8) - change "i.e." to "e.g"

12 - Page 26, Paragraph d - add "or should the individual be out of the commonwealth for more than 48 hours"

13 - Page 25, Paragraph 2 - Change "240" to "480".

14 - Page 26, Paragraph d - Change "240" to "480".

15 - Page 26, Paragraph 3.a. - Delete "specialized medical" from the first sentence. Change "ADLs" to "ADLs and/or IADLs".

16 - Page 28, paragraph a - Add to the end of the first sentence "and/or safety"

17 - Page 28, paragraph i - Add an additional sentence "However, repairs of the modifications are eligible."

18 - Page 29, paragraph (1) - Delete.

19 - Page 29, Paragraph e.(2) - Change "16" to "20".  Add to the end "and where 20 scheduled PDN and PC hours are not completed within a 24 hour period, the hours may be rescheduled and worked within the following 72 hours to support the primary caregiver."

20 - Page 41, Paragraph B.1 - Delete or update last sentence as it only pertains to 2011.

21 - Page 41, Paragraph B.2 - Add to the first sentence "as covered below".   Delete or update last sentence as it only pertains to 2011.