Virginia Regulatory Town Hall
Agency
Department of Medical Assistance Services
 
Board
Board of Medical Assistance Services
 
chapter
Waivered Services [12 VAC 30 ‑ 120]
Action Three Waivers (ID, DD, DS) Redesign
Stage Proposed
Comment Period Ended on 4/5/2019
spacer
Previous Comment     Next Comment     Back to List of Comments
4/5/19  6:55 pm
Commenter: Joy Spencer, CEO of Moms In Motion/At Home Your Way/Ability Unlimited

Public Comment by Moms In Motion/At Home Your Way (CDSF) & Ability Unlimited (DME)
 
  • 12VAC30-122-260. Services covered in the Family and Individual Support Waiver.  SF is not listed as a covered service.
    • OUR COMMENT:  Add Service Facilitation Services as a covered service.
  • 12vac30-122-20.  DEFINITIONS:  "Services facilitator" means (i) a DMAS-enrolled provider, (ii) a DMAS-designated entity, or (iii) one who is employed by or contracts with a DMAS-enrolled services facilitator that is responsible for supporting the individual or EOR, as appropriate, by ensuring the development and monitoring of the plan for supports for consumer-directed services, providing employee management training, and completing ongoing review activities as required. "Services facilitator" shall be deemed to mean the same thing as "consumer-directed services facilitator."
    • OUR COMMENT:  This needs to state "providing EMPLOYER management training," -- CDSF does not train the CD Employee.
  • 12VAC30-122-210. Payment for covered services (tiers)

    • C, 1 -- OUR COMMENT:  Detail that this $5000 is PER SERVICE and not combined

  • 12vac30-122-270

    • B, 2, d: “The AT service provider shall obtain, install, and demonstrate, as necessary, that the service was authorized prior to submitting his claim to DMAS for reimbursement. The provider shall provide all warranties or guarantees from the AT manufacturer to the individual and family/caregiver, as appropriate.”

      • OUR COMMENT:  The AT service provider shall obtain, install, and demonstrate, as necessary, that the service was complete prior to submitting his claim to DMAS for reimbursement. The provider shall provide all warranties or guarantees from the AT manufacturer to the individual and family/caregiver, as appropriate

    • “C. Service units and limitations. The AT service shall be available to individuals who are receiving at least one other waiver service and may be provided in a residential or nonresidential setting described in subdivision B 1 of this section. The AT service shall be provided in the least expensive manner possible that will accomplish the modification required by the individual enrolled in the waiver.”

      • OUR COMMENT:  The AT service shall be available to individuals who are receiving at least one other waiver service and may be provided in a residential or nonresidential setting described in subdivision B 1 of this section. The AT service shall be provided in the least expensive manner possible that will meet the needs required by the individual enrolled in the waiver.

    • C, 1. “The maximum funded expenditure per individual for all covered procedure codes (combined total of AT service items and labor related to these items) shall be $5,000 per calendar year and shall be completed within the calendar year. The service unit shall always be one for the total cost of all AT service being requested for a specific timeframe.”

      • OUR COMMENT: The maximum funded expenditure per individual for all covered procedure codes (combined total of AT service items and labor related to these items) shall be $5,000 per calendar year and shall be completed within one calendar year from the date of authorization. The service unit shall always be one for the total cost of all AT service being requested for a specific time frame. (rationale: if the EM is requested January 1 that would be a full year to complete it within the calendar year. However, if the request is made on December 1 that would be 30 days to complete it within the calendar year.)

    • C, 2. The AT service shall not be approved for purposes of convenience of the caregiver or restraint of the individual, recreation or leisure activities, or educational purposes.

      • OUR COMMENT:  Exception: for the health, safety and welfare of the individual when transported in a moving vehicle and individual exhibits needs that are beyond the use of standard automobile issued seat belts. i.e. booster, five point-harness, etc.

    • D, 8. “Additional charges for shipping, freight, or delivery are prohibited because these services are considered all-inclusive in a provider's charge for the product.

      • OUR COMMENT: To include net costs of products + 30% + shipping, freight or delivery costs

 

  • 12VAC30-122-370.  Environmental Modifications

    • C, 1. Environmental modifications (EM) service shall be provided in the least expensive manner possible that will accomplish the modification required by the individual enrolled in the waiver and shall be completed within the calendar year.

      • OUR COMMENT:  Environmental modifications (EM) service shall be provided in the least expensive manner possible that will accomplish the modification required by the individual enrolled in the waiver and shall be completed within one calendar year from the date of authorization. (rationale: if the EM is requested January 1 that would be a full year to complete it within the calendar year. However, if the request is made on December 1 that would be 30 days to complete it within the calendar year.)

    • E, 2. Provider documentation shall support all claims submitted for DMAS reimbursement. Claims for payment that are not supported by supporting documentation shall be subject to recovery by DMAS or its designee as a result of utilization reviews or audits.

      • OUR COMMENT:  Providers shall develop and maintain individual-specific documentation that support all claims submitted for DMAS reimbursement. (to include process and costs to obtain services, contractor’s design, estimate of materials, supplies and labor, etc) Claims for payment that are not supported by supporting documentation shall be subject to recovery by DMAS or its designee as a result of utilization reviews or audits.

CommentID: 71017