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On March 17, 2014, the Centers for Medicare & Medicaid Services (CMS) issued a final rule for Home and Community-Based Services (HCBS) that requires that all HCBS settings be integrated and support full access to the greater community for individuals receiving Medicaid HCBS. This includes opportunities to seek employment and work in competitive, integrated settings, engage in community life, control personal resources, and receive services in the community to the same degree of access as individuals not receiving Medicaid HCBS.

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As the deadline to fully comply with the final rule has passed, state legislatures, HCBS providers and other stakeholders are entering a new era of ensuring ongoing, meaningful implementation of the HCBS philosophy and HCBS settings requirements.

True community integration can be hard to achieve and maintain – starting with a provider’s understanding of requirements and willingness and ability to enforce compliance. Community integration isn’t about just getting out in public and experiencing the community apart from others. It’s not rented out movie theaters or bowling alleys or special times for people with disabilities at the local gym or library. It’s about facilitating and supporting the individual to access, utilize and engage in existing community resources just as anyone else. It’s about ensuring the individuals’ autonomy to make choices and to control their lives.

HCBS providers may be struggling with ongoing, meaningful implementation due to a variety of factors including the lingering effects of the COVID-19 public health emergency and subsequent staffing challenges as well as general misconception of the requirements. Providers may have difficulty striking a balance between maintaining a qualified workforce and supporting individuals receiving HCBS to live integrated lives in their communities. At the same time, it may be challenging to meet an individual’s health and safety needs while also ensuring the person’s autonomy in making decisions about their life. It requires a special skillset for the individuals providing HCBS and organizational commitment to change the culture of HCBS truly and effectively to successfully achieve this goal.

As state oversight entities implement their ongoing monitoring processes, it is important to acknowledge these potential barriers and challenges for the providers of HCBS and work collaboratively to identify solutions. True and lasting change can be achieved when everyone is committed to the same goal: real, meaningful integration that allows an individual to thrive and live their best life on their terms.

To learn about how Telligen helps states increase access to HCBS while improving service delivery, please visit our State Health Solutions resources page.