VOR’s comments relate to the three substantive sections of the proposed federal rule:
(I) Target Groups;
(II) HCBS settings (defining “community”); and
(III) Person-Centered Planning.
Click here to read VOR Comments: CMS-2296-P, April 15, 2011
On August 17, 2009, VOR submitted its comments in response to the federal Advance Notice of Proposed Rulemaking (ANPRM), released by the Centers for Medicare and Medicaid Services (CMS), the federal agency within the U.S. Department of Health and Human Services which oversees Medicaid programs. The ANPRM asked for comments relating to allowing states to combine home and community-based services (HCBS) waivers for people with different disabilties who have similar functional needs. CMS also sought input on how to define "community."
In its comment, VOR expressed significant concern that current state budget woes and administrative conveniences would prove too great of temptations to States, leading to dangerous comingling of people with incompatable disability-types, leading to tragic consequences. Many real life examples were cited to reinforce VOR's stated concerns. With regard to defining community, VOR pointed out that both facilities and smaller settings can be "integrated." Our comments reinforce the need for choice, and Olmstead's support for choice.