Argentum submitted a comment letter last Monday in response to a proposed rule issued in May by the Centers for Medicare & Medicaid Services (CMS), intended to increase transparency and accountability, standardize data and monitoring, and create opportunities for states to promote active beneficiary engagement to improve access to care, including in home and community-based services (HCBS) programs.

We recommended that CMS withdraw the proposed rule and instead work with stakeholders to identify other approaches, particularly by addressing the inadequacy of state Medicaid reimbursement rates for assisted living and similar residential communities participating in HCBS programs.