Thank you for the opportunity to provide comments on the draft Virginia Informed Choice (VIC) Form (DMAS-460) and Service Selection Guide. We appreciate the intent of these documents to promote informed decision-making, but we have identified several areas where revisions would strengthen clarity, usability, and compliance with federal and state expectations.
The draft highlights the need for a Regional Support Team (RST) referral when a provider operates with five or more residents. However, there is no user-friendly method to verify whether a home meets this threshold. This creates challenges for families using the Service Selection Guide independently and for Support Coordinators assisting them.
Recommendation: Modify the licensed provider search tool or the Service Selection Guide to display the licensed bed size for each provider. This will help families and Support Coordinators make informed choices and avoid delays caused by incomplete information.
The section titled “For support coordination I select:” may suggest that individuals and families can freely choose their CSB, though assignments are generally based on catchment area. While limited cross-CSB choice may exist through agreements, the current wording risks confusion.
Recommendation: Revise language to read, “For support coordination in my locality, I select:” to more accurately reflect the process.
Question #7 currently forces both “yes” and “no” checkboxes to be marked simultaneously, preventing accurate responses.
Questions #7 and #7a are overly broad, which could lead to vague or unusable answers.
Khuyến nghị:
Correct the checkbox coding to ensure responses are mutually exclusive.
Narrow the wording of Question #7 to: “Are any DD waiver services you are eligible for currently unavailable?”
The Service Selection Guide is a valuable resource, but attaching it directly to the VIC form creates an unnecessarily long and unwieldy document. Individuals already receive a full list of options during Individual Support Plan (ISP) meetings and upon request.
Recommendation: Keep the Guide as a separate reference, but include clear instructions and links within the VIC form directing families to the Guide and other resources.
The draft form only allows for documentation of the option ultimately selected, not all options presented. This is inconsistent with regulatory requirements and creates additional work for Support Coordinators, who must duplicate documentation in progress notes.
Khuyến nghị:
Expand the form to include multiple fields under each service category for provider names.
Alternatively, add a required attachment where all provider options must be listed.
Revise language from “I select…” to “Options discussed and my selection:” to ensure documentation reflects both the full range of choices and the final decision.
Unlike the electronic VIC used in RST referrals, the written form does not require provider names to be listed. Without this, there is no way to verify that families received meaningful choice.
Recommendation: Require at least two to three provider options to be listed per service category offered, consistent with federal HCBS expectations for informed choice.
Terminology such as “sponsored residential” or “RST referral” may be confusing for families completing the form independently.
Recommendation: Provide plain-language definitions or a glossary of terms within the written form, and include hover-over tooltips in the electronic version.
We support maintaining the current wording in Question #8, which prompts Support Coordinators to inform individuals and families about unpaid and community-based resources (such as peer mentoring, advocacy groups, and insurance-funded services). This reinforces person-centered planning and should remain in the final version.
Overall, the VIC form and Service Selection Guide are critical tools for documenting informed choice. The recommended revisions above will:
Improve clarity and usability for families.
Reduce duplicative documentation for Support Coordinators.
Strengthen compliance with 12VAC35-105-660.D and federal waiver requirements.
Ensure that all provider options—not just the chosen one—are consistently documented.
By making these adjustments, Virginia can enhance the integrity of the informed choice process and better support individuals and families in making meaningful, person-centered decisions.