Comments on New 1915(c)(11) Waiver Option
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In July, the MLTSS Association sent a letter to CMS outlining recommendations for the new standalone 1915(c)(11) waiver option allowing states to extend Home and Community Based Services (HCBS) to individuals who do not yet meet an institutional level of care (LOC) standard.
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MLTSS plans already deliver HCBS to people with complex and specialized healthcare needs under existing 1915 and 1115 frameworks, manage care coordination across the full continuum of LTSS, and possess the data infrastructure and population health capabilities needed to support states in operationalizing this new authority.Â
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Our recommendations reflect a strong belief that the new waiver option can advance prevention, promote independence and aging in place, and align with the administration's goals of improving care coordination and reducing unnecessary institutionalization.