WV Medicaid Recipients' Union : 1st Draft 2005 MR/DD Waiver Renewal Application Comments


◊ HOME ◊ CONTACT US ◊ MISSION ◊ MEMBERSHIP ◊ CALENDAR ◊ POSITIONS Comments ◊ COMMITTEES ◊ WV MEDICAID ◊ LEGISLATIVE ◊ ELECTIONS ◊ LINKS ◊ JOB MATCH	DRAFT 2005 MR/DD WAIVER RENEWAL APPLICATION COMMENTS
	Friday 18 March 2005 To: Nancy Atkins, Commissioner, BMS Eugenie Taylor , Commissioner, BHHF Steve Mullins , Office Director, OBAH, BMS Pat Winston , Program Manager II, OBAH, BMS Frank Kirkland , Director, Division of DD, BHHF David Majic , Director, OBHS, BHHF Martha Walker, Secretary, DHHR From: West Virginia Medicaid Recipients’ Union Debi Lewis , founder Re: Draft 2005 MR/DD Waiver Renewal Application On behalf of the WV Medicaid Recipients’ Union (MRUWV), I submit the following comments, questions, and concerns regarding the draft 2005 MR/DD waiver renewal application. First of all, I wish to commend the WV Developmental Disabilities Council (WVDDC) and its executive director, Steve Wiseman, for the timely preparation and prompt, widespread distribution of its feedback. It is very encouraging to see an advocacy organization so impressively rise to the occasion. MRU WV agrees with every point raised in the WVDDC materials referenced. On the evening of March 15, 2005, WV Waiver Families (WVWF) hosted an online chat to discuss the draft application. Over fifty (50) stakeholders participated statewide. Officials from DHHR and CMS were invited to participate. None chose to do so. While an online chat is not an ideal venue in which to develop feedback on such a critical issue, given the extremely short period for public comment, there was simply no other way to pull together stakeholders. The issues raised here and, by extension, in the WVDDC materials echo the discussion that took place online. In addition to the issues raised in the WVDDC materials, MRUWV adds the following: ADULT COMPANION CARE: For those individuals living with their families, this service would no longer be available. Families would thus be forced to use Respite Care – which is capped at 144 hours per month (in contrast to the 654 hours per month of available Adult Companion Care). This creates a disincentive for individuals to live with their families. Natural supports are the single most cost effective resource for individuals with disabilities. Every effort should be made to ensure that they are appropriately supported. PRIOR AUTHORIZATION: Clarification is needed on the requirement for prior authorization. The draft renewal application contradicts itself on this issue. LEVEL OF CARE: Clarification is sorely needed at the policy level regarding the provision of waiver services around the clock. The program’s stated intent is to increase independence through the delivery of habilitative training, yet individuals cannot enjoy the benefits of their progress without risking the loss of all program services. This contradiction not only drives program costs higher and defeats the purpose of a training program, but also violates the individuals’ rights under Olmstead. Individuals with available natural (free) or electronic (lower cost) supports are threatened with the loss of their waiver "slots." That is just plain wrong on SO many levels. CHOICE: While the WV DDC materials address this issue, it is of such vital importance that I must reiterate. There has indeed been a vast increase in the number of service providers over the last five years. This has NOT resulted in improved choice for the "consumer." Service providers pick and choose their clientele based on factors totally unrelated to capacity. They hold one service hostage to others (i.e., agreeing to provide service "A" if and only if the individual also agrees to allow them to provide service "B" as well). That is not "choice." That is coercion. Additionally, service coordination agencies often refuse to split services across providers (or even to allow natural supports) because of liability concerns. Policy desperately needs to address this. In summation, the proposed changes to the MR/DD waiver program (and indeed, the changes already adopted via the "new" waiver regulations – which were also pushed through with little/no opportunity for stakeholder input) do absolutely nothing to improve the lives of individuals with disabilities, to enhance their access to the homes and communities of their choosing, to encourage their independence, or to decrease their reliance on public assistance. Thank you for your time and very careful consideration of these remarks. If I can provide any additional information, please do not hesitate to contact me. With all due respect, // Debi Lewis // cc: Harry Mirach, CMS WV Waiver Families online support group Steve Wiseman , WVDDC Shana Phares , Deputy Secretary, DHHR David Sudbeck , Behavioral Health Ombudsman Jennifer Britton , APS HealthCare Jennifer Bundy, Associated Press ref: WV DDC memorandum "MR/DD Waiver Renewal Application Draft" (3/17/05) WV DDC document "Draft Application for Renewal Comments" (3/17/05)

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This page last updated Friday 17 June 2005