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The HCBS Advocacy Coalition Submits Response To CMS’ RFI

Ref: 42 CFR Part 440: [CMS–2404–NC] RIN 0938–ZB33. RFI: Federal Government Interventions to Ensure the Provision of Timely and Quality Home and Community Based Services.

The HCBS Advocacy Coalition appreciates the opportunity to respond to the Centers for Medicare and Medicaid Services (CMS) Request for Information (RFI) on federal government interventions to ensure the timely provision of quality home and community based services (HCBS). We appreciate the significant strides CMS has made to promote community integration for persons with disabilities and seniors. Expansion of HCBS options – including the Money Follows the Person (MFP) Program, 1915(i) HCBS State Plan Option, 1915(k) Community First Choice (CFC) Option, Balancing Incentive Program, and options for self-direction  have greatly increased the numbers of people able to live in their own homes and communities instead of institutions. Equally important, the 2014 HCBS Settings Rule help ensure that individuals living and receiving HCBS can truly experience the benefits of community life as intended by these programs. Moreover, the Americans with Disabilities Act’s promise of community access and integration for all is closer than ever, and it is important that CMS continue to help states move forward without delay.

The HCBS Advocacy Coalition is a partnership of organizations that supports the full inclusion of people with disabilities and aging populations in all aspects of community life. We believe that strong implementation of the new HCBS Settings Rule is critical to achieving systems change that results in truly integrated settings and services that promote truly inclusive lives in the community. We work collaboratively to ensure that implementation fulfills the Rule’s intent and spirit by assisting stakeholders in every state in understanding and engaging in implementation of the Rule. For more information about our coalition, see

We applaud CMS’s recognition that there is much more the agency can and must do to ensure the provision of timely and quality HCBS. As noted in the RFI, the voluntary nature of Medicaid HCBS options has resulted in significant differences in the availability of HCBS by population and by state, with far too many people being isolated in institutions and other segregated settings due to the lack of HCBS. At the same time, it is complex for states to navigate the various HCBS options and determine how to best combine multiple authorities to accomplish the goal of increasing services. Participants themselves need a sufficient well coordinated array of service options and the confidence that they will be able to find available well-qualified providers of these services.

We are pleased to offer the following comments and recommendations in response to the RFI.

Submitted by:

  • American Network of Community Options and Resources (ANCOR)
  • Association of People Supporting Employment First (APSE)
  • Association of University Centers on Disability
  • Autistic Self Advocacy Network
  • Center for Public Representation
  • Collaboration to Promote Self Determination
  • CQL | The Council on Quality and Leadership
  • Human Services Research Institute
  • Institute on Disabilities at Temple University
  • National Association of Councils on Developmental Disabilities
  • National Disability Rights Network
  • National Down Syndrome Congress
  • National Health Law Program
  • TASH
  • The Arc of the United States


Since 1969, CQL | The Council on Quality and Leadership has been a leader in working with human service organizations and systems to continuously define, measure, and improve quality of life and quality of services for youth, adults, and older adults with intellectual and developmental disabilities, and psychiatric disabilities. CQL offers accreditation, training, certification, research, and consultation services to agencies that share our vision of dignity, opportunity, and community for all people.