ANCOR posted the following public comment in response to the Centers for Medicare and Medicaid Services (CMS) proposed changes to the Managed Care Rule:
“The American Network of Community Options and Resources (ANCOR) is a nonprofit trade association representing over 1600 private providers of disability community services for people with intellectual and developmental disabilities in addition to 55 state disability provider trade associations. We are pleased to have the opportunity to submit our comments to this proposed rule. ANCOR commented extensively on the 2016 regulation and we affirm our comments from that rulemaking period.
As CMS considers further changes to the managed care regulation, we would respectfully make three key recommendations. First, given the unique challenges and opportunities of managed care in the I/DD system, we would urge CMS to integrate a perspective of home and community-based services and values into all parts of the rule so that application to this arena will happen more smoothly. Secondly, we highly encourage CMS to integrate ANCOR’s key principles for managed long term services and supports into the forthcoming rulemaking. Please see attachment for that full list of recommendations. Finally, as a partner in the effort, we highly recommend that CMS work on any changes to this regulation in concert with the Administration on Community Living (ACL) and the wonderful work of the HCBS Business Acumen Center that has focused on best practices for managed care in disability supports and services: http://www.nasuad.org/initiatives/hcbs-business-acumen-center.
Finally, as a national trade association that promotes a high quality of life for people with disabilities, we applaud CMS for recognizing the narrow definition of look disability and support recommendations to broaden it.
Thank you for reviewing our input. We hope to serve as a resource for the Centers in any way that is helpful and look forward to the final regulation.”
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