“Heightened Scrutiny Is Real. Use It.”

            – Ralph Lollar, Director of Long Term Services and Supports,
                               Disabled and Elderly Health Programs Group, CMS
                                speaking to state officials at the NASUAD HCBS Conference

 

Spokesmen for the Centers for Medicare and Medicaid Services (CMS) offered new clarification important to ADS/ADHC providers during several sessions at the National Association of States United for Aging and Disabilities (NASUAD) annual HCBS conference August 29th thru September 1st.

In short, the single word “unless” in the HCBS regulations provides the states and providers within them the opportunity to justify under the provision of heightened scrutiny continued Medicaid HCBS funding for ADS/ADHC services regardless of the physical setting as long as the person-centered, community quality requirements are met.

Although justification may be rigorous in some instances, this clarification is a significant step forward from an administration that previously seemed determined to prohibit any setting that was physically located within, on the grounds of, or next to an institution.

More information will be presented at the NADSA Conference September 21-23.

Roy C. Afflerbach, NADSA Public Policy Advisor