12VAC30-122-10 - #6 & #7 are transposed - Engagement should come before Guide / Guide is 12VAC30-122-330 and Engagement is 12VAC30-122-320

The following definitions are missing 12vac30-122-0: Independent Living & Workplace Assistance as well as the following reserved services: benefits planning, community guide, non-medical transportation, peer support 

12vac30-122-10: "Community Coaching" add "or to support an individual when there is an ongoing barrier to participation" 

QDDP - all references to QDDP should also reference reg 12vac35-105 for clarity and consistency 

Face-to-face Visit  - defiition needs to also explain that face-to-face is the quarterly visit/report done by administation agency for Shared Living 

Supported Living Residential - delete after the word service "taking place in an apartment setting" and change to "taking place in an individual's own home" - this stays consistent as "own home" is also defined and there is not reason to dictate what type of living arrangement a person should live in to receive a service. 

12VAC30-122-80 - C.4. change 30 days to 90 days. It is an unrealistic expectation to have all of the required components competed in 30 days regarding the application/interview/training process and the case management requirements. 90 days is more realistic and supports individuals to have time to make fully informed decisions and not feel pressured or rushed. 

12VAC30-122-90 - C.1.b.(1) - strike - "by the primary caregiver or unpaid provider" - not everyone has a primary caregiver and there is no operational reason to specify that in the regulations. 

12VAC30-122-120 - A.4. change 30 calenday days to 90 calendar days 

A.5. - strike "medically necessary services and supplies" and replace with "services and supports" 

A.6. - strike "supplies" and replace with "supports" 

A.10.3. - strike "such documentation shall be written on the date of service delivery" as this is not consistent with the definition of progress note 

A.13 - change 37.2-600 to 37.2-607 

D. strike "may" and replace with "shall" 

12VAC30-122-210 - A.4.e - change "individuals" to "each individual's needs" - the original language is not person centered 

12VAC30-122-310 - A - after barriers add "or to support an individual's participation when there is an ongoing barrier to participation" 

C.3 - Strike "this service shall not be provided within a group setting". THis is too restrictive and also implies seclusion of the individual owing to the barrier/participation in the service. How is the purpose and intention of Community Coaching supporting indviduals to integrate into community engagement going to be successful if the individual does not experience group settings? Additionally - if the individual's barrier is related to difficulties with group settings the current language will not allow for the service to be facilitated. 

12VAC30-122-390 - E.1.c - strike "at least a daily note" and replace with "a progress note" - to remain consistent with definition and other sections 

12vac30-122-420 - A - add following the words receiving this service "...lives, or is preparing to live, alone..." strike word "typically". As the regulation states that part of the intention of this services is to "secure" independent living it should also apply to those who have not yet secured it. 

E.1.c - add "Observations of individual's responses to services shall be available in progress notes." 

E.1.d - strike "and the documentation will correspond with billing" - as independent living bills once monthly as a single unit of billing the current language is inconsistent with the facilitation of the service. 

12VAC30-122-460 - strike all references to "companion" and replace with "Personal Assistance" 

B.4.E - strike "actitivities" and replace with "activities" 

12VAC30-122-530 - E.1.c - strike "confirming the amount of the individual's time in service and" - as Sponsor Residential no longer bills hourly the current language is not consistent 

E.1.c. - end of second sentence strike "at least a daily note" add "in a progress note" 

12VAC30-122-550 - delete after the word service "taking place in an apartment setting" and change to "taking place in an individual's own home" - this stays consistent as "own home" is also defined and there is not reason to dictate what type of living arrangement a person should live in to receive a service.