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Capitol Correspondence - 11.21.23

ANCOR Advocates for Deeper Recognition of Workforce Crisis in Proposed Section 504 Regulations

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Last week, ANCOR submitted comments on the proposed Section 504 regulations, expressing appreciation for the proposed regulations’ strong emphasis on integration while underscoring the pressing issue of the direct support workforce crisis and its impact on access to integrated settings.

The comments focused on concerns regarding the revised integration mandate in the proposed rule, including that the proposed rule’s inclusion of greater specificity than what is currently required under Title II of the ADA could potentially set up different standards between the enforcement of Section 504 and the ADA. The comments ultimately emphasize the importance of aligning these standards to ensure clarity and consistency in the regulatory landscape.

A key aspect of ANCOR’s comments addresses the challenges faced by community-based providers in ensuring adequate rates to meet individualized needs. The comments stress the need for recognition of these limitations and ask for recognition of the differing responsibilities of community-based providers and state entities.

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