On November 13th, 2023, ADvancing States, the National Association of Medicaid Directors (NAMD), and the National Association of State Directors of Developmental Disabilities (NASDDDS) submitted joint comments to the Centers for Medicare and Medicaid Services (CMS) on proposed revisions to the Medicaid 1915(c) waiver application and technical guide.
We support the intent of the proposed changes to bring the waiver application and technical guide into alignment with the final home and community-based services (HCBS) settings regulations, to ensure that every person receiving Medicaid-funded HCBS has full access to the benefits of community living. We raised concerns regarding the lack of engagement with our associations and state agencies to develop the proposed changes, and emphasized the importance of soliciting input from states to determine where clarification is needed, as well as to understand the impact proposed changes will have on states’ HCBS waiver programs.
The comment letter includes specific recommendations to CMS on individual revisions and the overall strategy for implementation.