I fully agree with the comments submitted by both ServiceSource and VaACCSES on specific regulatory language and concerns.

I want to additionally comment on the urgent need for DMAS and DBHDS to refocus on older individuals and their family caregivers., both in terms of the wait list and as older individuals become service recipients. 

12VAC30-122-90. Waiting list; criteria; slot assignment; emergency access; reserve slots

C.1.a. – Following care for the individual add “a primary care giver who is 70 years of age or older”. The age criterion of caregivers was removed during the "redesign".  The impact of thiis change was significant. ?In 2016, preceding redesign, the number assigned to urgent status was 4,943 and after redesign in 2017, the number assigned to priority one decreased by nearly half to 2,749.

In addition, I am personally very troubled by the significant number of individuals who remain on the Wait List and who themselves are over age 70.  Based on DBHDS data as of 2/1/19, there were 43 individuals over age 70 ON THE WAIT LIST.  Of these, 7 were priority one.  I recommend adjusting the definitions of priority status to ALSO address the age of the individuals waiting for a Waiver.  A measure of the age of the individual should assign these older individuals to a more urgent status for slot assignment.

12VAC30-122-200. Supports Intensity Scale® requirements; Virginia Supplemental Questions; levels of support; supports packages. 

I am concerned that the use of the SIS® is proposed to be limited to individuals under age 72.  The individuals that providers support generally experience significant increases in support needs as they age and stopping the use of the SIS at age 72 to assess these needs is completely counterintuitive.  Relying on an outdated assessment for older individuals is unsafe to the individuals. Additionally it imposes an additional burden on providers who are forced to rely on reimbursement rates based on outdated and inaccurate SIS scores.

I therefore support that “Individuals who are older than 72 years of age shall be assessed using either the SIS or an alternative instrument (with this alternative instrument or instruments to be named in the regulations).” 

Thank you for the opportunity to comment.