On May 20, the National Association of Medicaid Directors (NAMD), the National Association of State Directors of Developmental Disabilities Services (NASDDDS), and the National Association of States United for Aging and Disabilities (NASUAD) have sent a letter to the Centers for Medicare and Medicaid Services (CMS) concerning implementation of the new home and community-based services (HCBS) regulation. While acknowledging CMS' extensive effort to promote integrated living in the community, the letter raises several concerns regarding CMS' expectations for state implementation plans and ongoing compliance activities. The letter recommends two overarching steps that could facilitate a more efficient transition process for states, and ultimately to ensure Medicaid clients will be able to fully integrate into their communities. These steps are:
- Consistent coordination with several entities within the Department of Health and Human Services (HHS); and
- Ongoing collaboration with state agencies responsible for overseeing and administering home and community-based systems.
The letter goes on to offer more detailed explanations and recommendations in the following four areas:
- Develop a systemic approach to implementation;
- Convene with states to enhance the understanding of the settings requirement;
- Ensure consistent messaging from all HHS entities; and
- Educate audit and program integrity entities.
The HCBS rule went into effect on March 17, 2014, and states are currently at various stage in implementation and transitioning to the requirements of the rule.