These comments are on behalf of West Virginia Parent Training and Information, WV Family to Family, and Family Voices of WV.
My initial comment stems from the extreme need for the Department to follow the funding related to this program, rather than cut services. Many of the waiver provider agencies are making extreme profits. We need a system designed to manage and audit funds. For example, if ABC provider is receiving $40.08 an hour for nursing services and is only paying the nurse $14 to $17 an hour, where is the additional $23+ some dollars going? A strict 10% administrative overhead should be adhered to.
Many families that have called me say the exact same thing. If these changes occur, the state of WV will simply be trading one Medicaid dollar for another. Meaning, families will leave work to care for their children. They will give up jobs which will reduce tax contributions to the state. In addition, they will themselves sign up for benefits under the Medicaid system.
Home and community-based services were intended to reduce and eliminate the need for institutional life and provide opportunities for individuals to receive services in their own homes and communities.
I disagree with the addition of a minimum age of three as a qualification for this program. Especially, since families are waiting over two years to even get on the program. These are the most critical years for development in children.
The reduction in the units of Respite services being proposed will cause extreme difficulty for families to operate in a normal fashion. Family members need a break to complete many of the necessary activity's that provide stability for a family. I have seen no evidence that Respite services cause any financial problems to the current program. Furthermore, I oppose the restriction of the use of any other services on days Respite is accessed.
A maximum of only 2 hours of nursing services in unrealistic in many cases and may place many individuals at risk of neglect.
I am very unclear as to where the direction of proposed changes of combining of the Therapeutic Consultant and Behavior Support Professional means. This area is very vague.
Many children who fall under the medically fragile category and that are not able to attend public school do not always necessarily need assistance from Private Duty Nursing. It would make more sense and reduce cost to simply increase the hours of Person-Centered Supports.
As far as the proposed changes to Residential Habilitation, I completely disagree with the limits on family PCS services for children under the age of 18. The proposed maximum hours reduced down to six hours will severely limit the opportunity for parents to have a job. Therefore and again, most of the parents will leave work and be forced to enroll in Medicaid themselves as well as seek additional public assistance. Furthermore, who can train, assist and provide more consistency for an individual better than the person whom knows them best? This is the most beneficial service to individuals in this whole program.
I do approve of the change to transition individuals into settings that serve less than four individuals within a two year period in order to meet the new HCBS requirements. As far as forcing individuals to have a roommate, we feel this has extreme potential to cause privacy, financial and rights violations. All Americans have the constituted right to determine where they live and with whom.
Service Coordination- I appreciate that one of the requirements for Service Coordinators is to act as an advocate for the person who receives services. The problem is, it is seldom done. One of the reasons is that they do not receive adequate training, especially when it involved the school system or DRS. This is a service that could be provided by many organizations, including WVU CED.
I am also very apprehensive about caseloads being increased from 20 to 30 per service coordinator.
A maximum payout for PDGS and Environmental Accessibility of $1, 000 is a major issue. As technology advances, so does cost. Many of these modification, etc. are expensive, but also provide more independence in one's life. It's a wonderful trade off that in the long run reduces cost.
WVDE Policy 2419 - REGULATIONS FOR THE EDUCATION OF STUDENTS WITH EXCEPTIONALITIES - WV policy and procedures pertaining to early childhood and students 3-21 whose educational programs require special education and/or related services. http://wvde.state.wv.us/osp/policy2419.html
(IDEA)- Individuals with Disabilities Education Act a law ensuring services to children with disabilities throughout the nation. IDEA governs how states and public agencies provide early intervention, special education and related services to eligible infants, toddlers, children and youth with disabilities. http://idea.ed.gov
OSEP provides information, guidance and clarification regarding implementation of the Individuals with Disabilities Education Act (IDEA) in a number of ways including OSEP Memos and Dear Colleague Letters, and OSEP Policy Letters which can be found at: http://www2.ed.gov/policy/speced/guid/idea/memosdcltrs/index.html