I am writing in the hopes that you will reevaluate some of the restrictions of the Technology-Assisted Medicaid Waiver to better allow the families on this waiver to use the hours allocated WITHOUT REQUIRING ADDITIONAL HOURS, RESOURCES, OR FUNDING. 

Secondly if all those covered by the technology waiver have not received notification of these proposed rules and their ability to comment then the Department of Medical Assistance Services should notify them by mail and the comment period extended for 45 days from the date the notification is sent to them.

As the Aunt of a child who qualifies for services via the Technology-Assisted Medicaid Waiver, I have seen first-hand the benefits the waiver provides.  The in-home nursing care is a KEY part of the waiver which allows my sister and brother-in-law to hold steady jobs and manage a household all while creating a functional lifestyle.  As their work and personal life revolve around the nurses who help care for my nephew, missed nursing shifts have a huge impact on their lives.  I’m sure you realize and understand that children who receive 16 hours of Private Duty Nursing (PDN) care daily are among those who have the most involved and complicated medical needs.  Yet the families of these children are not afforded the opportunity to have missed shifts made up within a 72 hour period of time because of this one sentence:

(5) The making up or trading of any missed scheduled shifts, days or hours of care may be done within 72 hours of the missed scheduled shift but the total hours made up, including for any day, shall not exceed 16 hours per day for any reason.

To withhold from families whose children receive 16 hours of care per day the ‘make up’ hours they deserve is unconscionable.  This limitation should be removed and those cases receiving 16 hours of PDN should be given the same opportunity to make up missed shifts within 72 hours.  Their need to make up missed shifts is no less than the families receiving less than 16 hours of care each day.

In addition, I strongly recommended that PDN hours be allocated on a weekly basis in lieu of a daily basis which would allow for increased flexibility to better provide for the varied needs of the recipient families.  The total number of hours used on a weekly basis would remain the same.  This small accounting change would allow for families to use the hours they are allocated in the way that best fits their needs and would also allow for minor adjustments to schedules affected by missed shifts.

Thank you for taking the time to read my comments and fully evaluate how these recommendations could make a significant difference in the lives of the families your department supports.

--Susan Schools
Glen Allen, VA