Public Comments for 09/04/2025 Disability Commission
The Disability Advisory Commission, the Virginia Assembly and the Governor cannot make informed budgetary decisions without a full review of how much ALL categories of DD support services cost. The urgency of this issue means the Commission must alert the Governor’s office immediately to include all 21 categories of DD waiver reimbursement rates in the DMAS-Guidehouse study now. I write with great concern about a significant oversight in the DMAS-Guidehouse rate study underway for the 2026 General Assembly to rebase DD waiver reimbursement rates for the next biennium whereby almost half of the rates are not included this rate study. This oversight is discriminatory to Virginians with complex disabilities who have higher support needs and are dependent upon traditional core disability support services such as group homes, day programs and group supported employment. The DD Waiver Service rates included – and excluded - from the DMAS-Guidehouse Study are detailed in the attached summary. In total 10 out of the 21 available DD waiver service rates have been excluded from the DMAS-Guidehouse study and these categories predominantly support Virginians with the most significant disabilities. These core services such as group homes, day programs and group supported employment are critical for these Virginians to live and function safely in their community. DD waiver service rates are already substantially below market levels. Without substantial rebasing, this model will not be sustainable for service organizations to provide long-term. Providers cannot afford to expand based on DD waiver funding alone and need substantial outside support to operate. Already this year a local non-profit service provider, JDI, announced closure of all its group homes and group supported employment programs. Providers cannot offer programs and services cannot be sustained if there is not enough staffing due to discriminatory and low pay rates. As the parent of a 30 year old son with multiple disabilities (and a member of Arlington County DD advisory committee for 8 years), I have directly experienced, and witnessed countless other families, whose adult children with disabilities are not able to be served in their community. Inadequate pay has led to high staff turnover across the board and this loss of experienced personnel means that individuals with medical needs (eg. diabetes, epilepsy, etc) cannot be accommodated. Inadequate staffing ratios are directly impacting service providers’ ability to safely operate these day programs and residential services. Arlington is already running out of day program capacity,and programs are projected to be oversubscribed by September 2026. I am extremely concerned that this development will further erode the services on which adults with disabilities like my son depend.
Comments to the Virginia Commission for Disabilities Subject: DD Waiver Services and Funding Issues Every day in Virginia, thousands of individuals with developmental disabilities rely on services that are underfunded and understaffed. My name is Joanne Aceto, and I serve on the Board of Directors for vaACCSES, a statewide trade association whose members support over 50,000 Virginians with disabilities. For 50 years, vaACCSES has championed sustainable, high-quality services across the Commonwealth. I have dedicated my entire career to the IDD field. Concerns with the Rate Study I participated in the IDD Rate Study Work Group convened by DMAS and facilitated by Guidehouse. The draft rate study focused on 11 services identified in the DOJ Permanent Injunction as set forth by the General Assembly. While the study proposes an average rate increase of 18% for these services, we strongly urge the Commission to review the data and methodologies used. This increase does not adequately reflect the true costs of care and fails to address the systemic issues facing our service delivery system. Omitted Services of Concern The following essential services were excluded from the study: • Group Supported Employment • Group Day Support • Consumer Directed Services • Shared Living • Supported Living • Sponsored Residential • Group Home Residential • Crisis Support Services • Personal Emergency Response System These services form the backbone of Virginia’s disability service system. Their exclusion perpetuates rates that fall below actual costs and fails to provide adequate compensation for Direct Support Professionals (DSPs). It is unacceptable that the same flawed methodology may be applied to these omitted services, resulting in continued inadequate rates and wages. Workforce and Sustainability Virginia must adopt a rate-building process that reflects true and real costs for all services. We must ensure a sustainable and growing service system—not only for those currently receiving services but also for those still waiting. DSPs deserve living wages and benefits. They must be well-trained and compassionate to effectively support individuals with disabilities. Without fair compensation, we risk losing the workforce that is the foundation of our care system. Administrative Burden Additionally, the proposed cost reporting requirement introduces yet another unfunded administrative burden on providers, further straining already limited resources. Conclusion and Call to Action Virginia stands at a critical juncture. A sustainable, equitable system requires rates that reflect the true cost of care—not constrained historical spending. We urge the Commission to recommend decisively to adopt a transparent, cost-based methodology, include all omitted services, and ensure DSPs are paid a living wage. The future of disability services in Virginia depends on it. Thank you for your attention to these critical issues.
My name is Lynne Kozma and I’m the parent of a 35 year old disabled adult with cerebral palsy and a quadriplegic in a power wheelchair.. My son needs total physical support with feeding, dressing, bathing and toileting but also has good cognitive abilities and understands everything going on around him. He lives in a group home and attends a day program and thoroughly enjoys both of these services. In the last 6 months, I have been concerned about the constant turnover of the weekend staff at his group home. The turnover is caused by the low salaries of the staff that are caring for individuals, like my son, who have complex medical and mental issues that require training and, more importantly, a commitment to take care of our disabled. If we want this commitment from our staff, then we must make the commitment of a reasonable salary to them. My experience has been, in the last 4 years, that the group home staff, for the most part, takes pride in their work and deserve our support. Please raise the rates for the IMPORTANT services of group homes and day programs for the disabled. Thank you!
Submitted by: Maria McWhirt, PhD MPower Me, LLC VaACCSES Board Member I am a Virginian parent of an adult with DD who has experienced 8 years on the waiting list and the CCC+ waiver, and now 3 years with a DD waiver. I also serve on the Board of Directors for vaACCSES, a statewide association representing DD providers for over 50 years, and founded a special needs software development company that was an enrolled waiver provider for 5 years. Please see attached for my full comments.
The attachment is a statement of the background and issues associated with the 2025 DMAS-Guidehouse study of Medicaid waiver reimbursement rates for developmental disability (DD) services.
To: Virginia Disability Commission Re: DD Waiver Reimbursement Rates and the recent Rate Study On behalf of VaACCSES—the statewide association representing community-based organizations serving over 50,000 Virginians with intellectual and developmental disabilities—we appreciate the opportunity to provide comments on DD waiver reimbursement rates and the impact on individuals and service providers. Recently, Guidehouse, a contractor for DMAS completed the process for a rate study for eleven services as required by the DOJ Permanent Injunction. The stakeholder input was minimal throughout the process. In consultation with other stakeholders, vaACCSES found several components of the methodology to be flawed and inconsistent with best practice. In addition, to support the commitment to providing high quality services to all Virginians with intellectual and developmental disabilities, the rate study should encompass all DD waiver services to ensure equitable access to all desired services. 1. Inadequate Benefits and Wage Analysis The draft significantly underestimates employee benefits costs. Guidehouse uses a $621 monthly health premium—at the low end of Virginia's 2023 market range ($617-$772)—and assumes only 45% of full-time staff elect coverage. Providers need benefit packages approximating 30%+ of wages to recruit and retain quality staff due to current predictions that health insurance costs are likely to rise 30% in the coming year. 2. Insufficient Geographic Adjustments While the draft proposes higher rates for Northern Virginia, the geographic analysis is too limited. VaACCSES analysis of the same Economic Policy Institute data cited by Guidehouse reveals that several non-NOVA localities—including Charlottesville City and Albemarle County—have cost-of-living indices matching or exceeding some NOVA areas. A threshold-based approach should apply higher rates to any locality above a specified cost index. VaACCSES urges the following: • Adopt a true cost-based rate model starting from realistic direct care wages, full benefits packages (health insurance at actual market rates with realistic participation levels), appropriate supervision ratios, and necessary administrative overhead. • Preserve individualized rates for high-need cases through enhancements or add-on rates for situations requiring specialized care or additional staffing. • Expand geographic adjustments beyond NOVA using a threshold-based approach that includes all high-cost localities identified by EPI data. • Ensure data transparency by validating survey inputs, adjusting outlier values, and documenting all formulas and assumptions. • Address pay equity across all services to prevent disparities between DSPs doing similar work in different service categories. The current draft rate methodology will not generate sufficient rates to maintain a stable provider network to maintain quality services. Virginia's recent settlement agreement with DOJ requires implementing rate study recommendations—making it essential that this study reflect true service costs rather than historical underfunding. VaACCSES remains committed to partnering with DMAS to develop rates that are fair, transparent, and adequate to sustain high-quality services. We urge substantial revision of the methodology to prevent system collapse and instead support a thriving network serving Virginians with disabilities. Respectfully, Deanna Rennon vaACCSES Board President
Dear Chair Laufer and Members of the Virginia Disability Advisory Committee, We are parents of an adult son who depends on developmental disability (DD) waiver services for support. We are writing to ask the Commission to use its authority to ensure that all DD waiver services are considered for rate increases in the upcoming General Assembly session. Our son lives in a group home and receives support for his considerable needs from staff members of a Virginia nonprofit organization. The staff are dedicated and caring people but juggle multiple jobs and difficult work hours during the 24 hour/7 day a week schedule. The stress of caring for a household of young men with complex medical and behavioral needs is exhausting, often leading to staff burnout and turnover. Each time a staff member departs there is added pressure on those remaining to fill the gap along with the need to recruit and train new staff. The hours are long and schedule inconvenient, wages are low, and the work is difficult and unglamorous. The fact remains that the pay rates must increase to living wage levels to attract well qualified individuals and to fairly compensate staff for their service. The same situation exists in day programs, where our son spends 9am to 3pm Monday through Friday. Staff to participant ratios are stretched by the difficulty of attracting qualified people to these jobs, which in turn leads to burnout and substandard care. We continue to be concerned that without full review of waiver rates across all service categories, those our son receives, and we as parents rely on, will continue to weaken and deteriorate. Thank you for your thoughtful consideration of our request. Respectfully submitted, Dena and Rutton Patel 7887 Jones Branch Drive, McLean VA 22102 703-216-1431
Comments Document
Please see attached file: Public comment of Mara Flynn, Arlington, VA to the Disability Advisory Commission Members