ANCOR’s written comments submitted to the U.S. Centers for Medicare & Medicaid Services (CMS) proposed rule, were featured a in Home Health Care News alongside other commenters to the rule. While expressing gratitude and appreciation for CMS’ attention to the direct care workforce crisis, the article addressed concerns with the rule’s proposal to require at least 80% of Medicaid reimbursement for certain services be spent on direct care compensation.
The proposed rule has generated over 2,100 submissions during its public comment period. Some commenters, like Darby Anderson, EVP and Chief Government Relations Officer for Addus HomeCare Corporation, questioned the feasibility of implementing a standard 80% threshold across states with varying program requirements and reimbursement rates. Others, like the Partnership for Medicaid Home-Based Care, offered survey data indicating if implemented, the proposal would force service closures and high rates of inability to accept referrals. Concerns centered on how this approach could inadvertently lead to unintended consequences and potentially limit individuals’ access to crucial services and supports.
ANCOR endeavored to put forward a measured perspective in its comments, stressing the need for nuanced analysis in evaluating the proposed rule’s potential impact without risking access to home and community-based services. The featured quote drew concern to the underlying data cited in support of the proposal, which reflected state payment structures inconsistent with the proposed home and community-based service payment adequacy rule. ANCOR’s comments also highlighted the impact of the direct support workforce crisis on access, the necessity for transparency in rate-setting, and the importance of stakeholder engagement rate-setting activities and frequency of rate review. As the public comment period for the proposed rule has concluded, community stakeholders await further steps from CMS.
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