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ASAN Public Comment on Defining Home and Community Based Services
June 28, 2012 | admin
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The Autistic Self Advocacy Network applauds the Centers for Medicare and Medicaid Services’ decision to move forward on regulations defining the scope of settings acceptable under the 1915i state plan option. We concur with CMS that this definition, once final, should be applied under other HCBS funding streams, such as the 1915c waiver program. At the same time, we believe that the shift in requirements from CMS’ April 15, 2011 Notice of Proposed Rulemaking (CMS-2296-P) to the current NPRM (CMS-2249-P2) would allow states to utilize HCBS funds to support settings which are clearly not home and community-based. We urge CMS to consider the following recommendations to bring the proposed rule in compliance with the spirit, purpose and intent of the HCBS program.
Requirements of Provider-owned and controlled residential settings
We believe that housing and service provision should be de-linked entirely and would find it preferable to see a regulation that precluded provider-owned or controlled residential settings from receiving HCBS funds at all under the [...]