The Virginia Association of Centers for Independent Living (VACIL) is a statewide association of Centers for Independent Living (CIL) that advocates for the integration and inclusion of people with disabilities into all aspects of society. A CIL is a consumer-controlled, community-based, cross-disability, nonresidential, private, non-profit agency that is designed and operated within a local community by individuals with disabilities and provides an array of independent living services. VACIL offers the following public comment in response to the periodic review of 12VAC35-230, Operation of the Individual and Family Support Program.

The application process should prioritize applications based on the individual’s access to other supports. For example, individuals who have access to the CCC Plus Waiver personal care, respite, skilled nursing, adult day health, assistive technology and home modifications should not receive IFSP funding before individuals without access to CCC Plus Waiver services.

DBHDS should either notify all individuals on the waiting list at the same time about the application process and timeline or require the Community Services Board to do so. The lack of consistent information available to people on the waiting list must be addressed to ensure a fair process.

DBHDS or the Community Services Boards should provide direct assistance with the application process to people with disabilities within a timely manner. Assistance should include access to a computer and assistance with completing the application.

The application process should be announced no less than 90 days prior to the start of the application timeline.

If there are more people who apply in an application period than funds are available, individuals who were funded in the previous application period should not be funded until those who did not previously apply are funded.

Thank you for this opportunity to provide public comment.