The Virginia Association of Community Services Boards (VACSB) appreciates the opportunity to comment on these regulations.  VACSB has actively supportive of the ability for individuals with serious mental illness receiving the Auxiliary Grant to have greater flexibility and independence in their choice of living arrangements.  We are thrilled that 60 individuals finally have that chance.

VACSB would like to call your attention to one provision; however, that seems unnecessary given the pathway to qualifying for the Auxiliary Grant in Supportive Housing program.  

The regulations provide that the Universal Assessment Instrument will determine eligibility for AGSH, and “[e]ligible individuals shall be notified of the SH setting option and the availability of approved SH providers at the time of their annual level of care assessment.” Under this process, AGSH is offered to qualified individuals at the time of annual assessment.  The regulations appear to restrict this process to individuals currently residing in assisted living facilities. 

There is no reason to limit access to the AGSH only to those qualified individuals who reside in ALFs. The Uniform Assessment Instrument has been adopted for use by all publicly funded long-term care services, according to the official User’s Manual for the UAI. Therefore, the regulations should recognize a process for the identification of supportive housing in the UAI while an individual is residing in a state mental health facility prior to discharge. This process would be consistent with the language of Virginia Code, Section 51.5-160(E), stating that an individual may select supportive housing at the time of the first annual assessment.

Thank you for your consideration.