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The Service Selection Guide and VIC clearly discuss the need for an RST referral when a person is selecting a service where 5 or more people will be living. However, there is not currently a user-friendly way to determine if a group home is licensed for 5 beds or more. Many families may opt to use the Service Selection Guide to locate providers on their own and not realize that the provider they would like to select is licensed for 5 beds or more. Without having an easy to access database of these providers, it is challenging for Support Coordinators to make this determination when providing options to individuals to make their selection. Asking providers to send a physical copy of their license is not a reasonable expectation given the fact that DBHDS Office of Licensing already maintains a licensed provider search which indicates the service the provider is licensed to provide. Modifying the Service Selection Guide to include a separate listing of group homes which are licensed for 5 or more, or modifying the current licensed provider search to include the number of beds a provider is licensed for will support individuals and their families in informed decision-making as well as ensure Support Coordinators have the most up to date information related to a group home's bed size.
On the top where is say For support coordination I Select: and give a place for CSB and support coordinator name. This feels like you get a choice in CSB, which is based on location. A better wording might be For support coordination in my locality, I select:
For question #7, the checkbox does not allow you to choose either yes or no and automatically checks both options at the same time.
We are required to enter all decisions even if the service/agency was not chosen by the individual/SDM; however, there isn’t any drop down boxes or enough space to write in all options discussed.
For example, there are only three drop down boxes for “where I live”. What if I offered sponsored residential (3 different agencies discussed), sponsored living (2 different agencies discussed) and in-home supports (4 agencies discussed), where is that captured as there’s not enough drop down boxes to list multiple agencies, or characters available to type each agency, or enough space on the written form. The goal is to provide choice, how do we capture we’ve done so?
Also, It says “I select…”, that reads like we are only required to list the chosen service versus all decisions (as stated in the directions).
I am a provider that was cited for not having documentation in place related to 660.D by the Office of Licensing. I had the VIC but was told that is only allowed for case management. This document states that the VIC satisfies OL regulations for 660.D. I am glad to see DMAS has talked with the Office of Licensing and the VIC now meets that requirement for everyone.
#2: Note: Most people are not aware of the Peer or Family Mentoring Services. I would reframe the question: Did you receive information about the Peer and Family Mentoring Services? #2a: Did you receive information how to connect to services?
#3-6: For supports where I want to live, want to work, my community of choice, other services of interest.
#7: Are there any services requested but not available? #7a: If yes, identify steps for resolution & connection.
#8: The Support Coordinator explained services and options available in my community, the benefits and risks of those services, and I accept my choices.
#3-6: CMs are required to show options that were provided to the individual/guardian for different services. This new VIC only has the option to show the option that was selected making the CM have to take an additional step to clearly document all presented options in a progress note. This is an additional step that now needs to be taken by CMs, but also by auditors and reviewers instead of it being in one place as it currently is.
#7: Checkboxes are broken and only allow both to be checked, not either or.
#8: I like the current wording as it ties into the Part IV unpaid relationship discussion on the ISP and prompts the CM to inform individuals/guardians of other community options that may be available (ex: Arc, Best Buddies, insurance funded ABA or therapies, etc.)
I am against having the service selection guide attached to the VIC. This is already provided in the form of the DD Waiver Services and Support Options at the time of the ISP meeting and again when requested. Attaching it the VIC makes the form unnecessarily long and also prevents it from being kept by the individual/guardian to review at a later time.
In reference to the Support Coordination options at the top, the current wording is appropriate as individuals/guardians do have choice in CSB as well as case manager. While CSBs operate within a particular catchment area, all CSBs have agreements with surrounding CSBs to provide choice in case management services. This is an important fact for families to know and show this choice.
If DBHDS is serious about informed choice, they should start by producing a guide that families can actually read, that reflects current policy, and that is vetted before being circulated. Instead, this appears to be a bureaucratic cut-and-paste job hastily dumped onto the public, complete with grammatical and spacing errors.
This hyperlink doesn’t work:
Search for DBHDS licensed providers and view the locations, investigations, and inspections for selected services at: https://vadbhdsprod.glsuite.us/GLSuiteWeb/Clients/vadbhds/Public/ProviderSearch/ ProviderSearchSearch.aspx
This hyperlink doesn’t work:
If you have questions about Peer Mentoring contact: The Arc of Virginia at 804-649-8481 or at thearcofva.org.
Employment and Community Transportation:
Why are you referring to an “anticipated start date of 2019”, six years ago, when the latest Code of VA reg was March 31, 2021?
I was under the impression that this form was designed (and needed) to show that an individual had an informed choice of providers when choosing service providers. This form only shows the providers that have been chosen, not the ones that were declined. If there is NO requirement to document the providers who were not chosen, this is fine. But per Kaitlyn Graham's comment, if this is still a requirement, this form creates an additional documentation need and needs to be revised to complete the full required task.
The effectiveness of the VIC process depends heavily on the Support Coordinator’s ability to guide individuals through their options. To promote consistency and fairness across the state please consider implementing standardized training that emphasizes presenting service options objectively and supporting decision-making without bias.
Additionally, this version of the VIC appears to be written from the perspective of the individual, even though it is completed by the Support Coordinator. This can lead to confusion on who fills it out and should be clarified. While there is a signature line for a SDM, the form does not clearly indicate when an individual has a guardian involved in decision-making. Including a dedicated section to document guardianship status would improve clarity and ensure appropriate representation.
Another concern is the limited space provided to document multiple service options and providers that were explored and the reasons why certain options were not viable. This information is essential, not only to demonstrate that informed choice was offered, but also to help the RST understand what has already been considered and why those options may not have worked. Expanding this section would enhance transparency and support more effective planning.
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.
Thank you for the opportunity to provide comments on the proposed changes to the Services Selection Guide and Virginia Informed Choice Form.
The Arc of Virginia promotes and protects the human rights of people with intellectual and developmental disabilities and actively supports their full inclusion and participation in the community throughout their lifetimes. We know that the two documents under consideration are critical to ensuring people with disabilities and their families have opportunities to participate in meaningful decisions about their lives. The recommendations below will help users understand and engage with these documents and achieve optimal outcomes.
Services Selection Guide Recommendations:
Virginia Informed Choice Form:
Thank you again for the opportunity to provide input, and please let us know if you have any questions about the recommendations above!