The cross-disability Wisconsin Survival Coalition is comprised of more than 20 statewide disability organizations in Wisconsin with a mission of improving services and supports so people with disabilities can fully participate in their communities. We appreciate the opportunity to provide public comment on the Ensuring Access to Medicaid Services rule (file code CMS-2442-P) and the interest CMS has in ensuring state Medicaid LTSS programs are maximizing the use of home and community-based services so people with disabilities can live healthy, safe, community-connected lives. Our experience in Wisconsin demonstrates that to ensure access to appropriate home and community-based long-term care services and supports (LTSS) we need federal regulations and more federal guidance to:
- ensure rates reflect the actual cost of care,
- address the care worker shortage with multiple strategies,
- ensure the provider network can provide the level of authorized services,
- drive states to evolve service systems, lower cost, less staff intensive, more inclusive, and best practice approaches, including community supported living and integrated employment as the first and preferred option,
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