NAMD, ADvancing States, and NASDDDS Submit Joint Comments on CMS’s Access Rule

On July 3, NAMD, ADvancing States, and the National Association of State Directors of Developmental Disabilities Services (NASDDDS) submitted joint comments on CMS’s proposed access rule. These comments focus on the home and community-based services (HCBS) provisions in the rule.

In this letter, NAMD, ADvancing States, and NASDDDS voice our support for CMS’s goals for the Medicaid HCBS system, including smoothing access, promoting awareness of Medicaid-funded HCBS, addressing disparities of experience and outcomes, and ensuring high-quality and timely receipt of services. The proposed policies, however, face several key implementation constraints, including challenges around data collection, the need for additional specificity in sub-regulatory guidance, and significant time and costs associated with the required systems work. To address these challenges, we request that CMS extend the time frames for implementation and allow additional flexibilities.

You can find our joint association comments on the access rule here.

You can find NAMD’s standalone comments on the managed care rule here and the access rule here.