(Alexandria, Va.) – Maggie Elehwany, Argentum Senior Vice President, Public Affairs issued the following statement.
Today, Argentum submitted public comments in response to the Centers for Medicare & Medicaid Services (CMS) Proposed Rule entitled “Ensuring Access to Medicaid Services,” published on May 3, 2023.
Argentum supports the goals of CMS’s Proposed Rule to improve access to care for Medicaid beneficiaries and address health equity issues in the program, and agrees that more needs to be done to address shortages in the direct care workforce. These individuals are central to the senior living workforce and are at the heart of many of the services our members provide.
However, Argentum is concerned that CMS’s proposal to require that 80 percent of state payment for certain Home- and Community-Based Services (HCBS) be allocated to compensation for direct care workers is not the right approach to address these workforce shortages or increase access to services for Medicaid beneficiaries.
In its current form, the proposed rule is ambiguous, making it unclear whether and to what extent this policy would apply to assisted living or similar residential facilities that provide HCBS under state Medicaid programs. Furthermore, to the extent the policy would apply to such communities, Argentum is concerned that, without also addressing inadequate reimbursement rates, the proposal to only allow providers 20 percent of Medicaid payments to address all other expenses will make it very difficult, if not impossible, for these communities to continue current Medicaid operations. This could force communities to either reduce HCBS services they are currently providing, or cease participation in the Medicaid program altogether, which ultimately would have a negative impact on direct care workforce participation and Medicaid beneficiary access to care.
Without assisted living as an option, as many as 60 percent of senior residents could be forced into skilled nursing facilities, which are typically double the average cost of assisted living. By some estimates, assisted living saves Medicaid upwards of $40 billion annually. If finalized as currently written, this proposed rule could lead to the unnecessary utilization of Medicaid skilled nursing care in more restrictive settings and at substantially higher cost, placing further pressure on state and federal Medicaid budgets.
Argentum recommends that CMS withdraw this proposed rule, and instead work with stakeholders to identify other approaches to remedy this issue, particularly by addressing the inadequacy of state Medicaid reimbursement rates for assisted living and similar residential communities participating in HCBS programs.
Argentum’s comment letter can be found at: https://www.argentum.org/wp-content/uploads/2023/07/Final-Argentum-Comments-07032003-CMS-NPRM.pdf
The proposed rule can be found at: https://www.federalregister.gov/documents/2023/05/03/2023-08959/medicaid-program-ensuring-access-to-medicaid-services
About Argentum
Argentum is the leading national association exclusively dedicated to supporting companies operating professionally managed, resident-centered senior living communities and the older adults and families they serve. Since 1990, Argentum has advocated for choice, independence, dignity, and quality of life for all older adults.
Argentum member companies operate senior living communities offering assisted living, independent living, continuing care, and memory care services. Along with its state partners, Argentum’s membership represents approximately 75 percent of the senior living industry—an industry with a national economic impact of nearly a quarter of a trillion dollars and responsible for providing over 1.6 million jobs. For more information, visit www.argentum.org.
Contact:
Michael Keegan
Manager, Media and Public Affairs
ARGENTUM | Expanding Senior Living
1650 King Street, 6th Floor
Alexandria, VA 22314
703-599-7412 | [email protected]
