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Call for Comments — CMS Home and Community Based Services Waivers | DDadvocates.com

This is a time of tremendous change regarding funding, ideology and governance of the service delivery process for persons with Developmental Disabilities.

  • Federal funding is threatened as never before by proposals such as those put forth by Representative Ryan. Ryan   set his sights on Medicaid, the government health insurance program for the destitute and disabled. Of the more than $4 trillion he would cut from federal spending over the next decade, GOP aides say roughly $1 trillion will come from restructuring the way Medicaid works. Read more: http://www.politico.com/news/stories/0411/52499.html#ixzz1O35RrUSn
  • Ideology is becoming more rigidly entrenched in a system which often minimizes the value of family involvement and favors a one dimensional, full inclusion model for all persons with developmental disabilities without regard for their capabilities, or personal desires and choices.
  • Common-sense, which says keep what is good  and build on it, is ignored.
    • It would define a success as a community that provides a full spectrum of  services to meet the needs and desires of all persons with developmental disabilities—from the most involved to the most independent; and it would allow individuals the right to move back and forth between settings as their circumstances and desires changed.
    • Instead current ideology sees all ‘consumers’ including the most disabled living in completely integrated settings; something many neither want nor can handle. In addition it threatens funding for even the most successful ‘congregate settings’ based on artificial criteria like the number of residents or workers, or flexibility of meal time rather than real benchmarks like the quality of supports provided and the desire of clients to participate there.
  • Advocacy agencies including several in Michigan envision the elimination of all congregate settings and activities (group homes, work shops, Special Olympics, Fun Clubs and so on).
  • Change in governance is inevitable but will be driven by the new administration in Lansing (currently posting the position of Director of  Behavior Health and Developmental Disabilities) and in Wayne County by the retirement of Veda Sharp, Executive Director of the Detroit-Wayne County Community Mental Health Agency.


Most imminent of these issues are proposed regulation changes impacting the Home and Community Based Services Waiver administered by the Centers for Medicare and Medicaid Services (CMS). CMS is soliciting comments on proposed new regulations with responses due by June 14. If you are not familiar with the waiver, link to the ddnewsblog post on Understanding HCBS Waivers:  http://http://theddnewsblog.blogspot.com/2011/05/understanding-michigans-hcbs-waiver-for.html  

In addition Jill Barker, the editor of the ddNewsblog has compiled a document which represents an advocate-parent’s concerns with ideology that:

  • consistently pushes for more when there is less funding
  • assumes every person with developmental disabilities can fit into one program
  • defunds existing programs to support new ones without giving recognition to appropriate activities, to existing friendships and to the desires and capabilities and choices of the clients in the shuttered programs.  


You can find Jill’s entire comment document at the following link. Be sure to read it in order to understand the implications that are important to you. http://ddadvocates.com/2011/06/01/comments-on-cms-proposed-regulations-on-home-and-community-based-services-waivers-cms-2296-p/_____________________.

Comments on the Centers for Medicare and Medicaid Services (CMS) proposed regulations on Home and Community Based Services Waivers [CMS-2296-P].’..

Link to the proposed CMS regulations: http://edocket.access.gpo.gov/2011/2011-9116.htm


Comments on the proposed CMS regulations are due by 5pm on June 14, 2011.

In commenting, refer to file code CMS-2296-P .

Submit comments electronically herehttp://www.regulations.gov/#!submitComment;D=CMS-2009-0071-0302. This is a quick and easy link for electronic commenting.

This may be a once in a decade chance for individuals and families to help define what successful supports should look like in each State. Please read Jill’s document, consider our concerns and add your voice by the 14th.


As always, we will be pleased to post your comments.


Finally – to this year’s Michigan Special Olympics Track and Field Athletes – Good Luck and God Bless!!!

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One Response to “Call for Comments — CMS Home and Community Based Services Waivers”

  1. Mary Smith says:

    thnak you for posting this interesting article, and advising peoples, you are great

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