On April 8 the National MLTSS Association sent a letter to CMS to provide feedback and recommendations on the implementation of Section 9817 of the American Rescue Plan Act (ARPA) of 2021.
The Association recommends the following principles as CMS considers the implementation of the new funding stream:
- Disbursement of funds to states should begin as soon as possible and be based on a simple and
streamlined process so that states can in turn quickly distribute the funds to the HCBS system;
- Use of funds should be solely focused on directly enhancing, expanding, and strengthening HCBS;
- States should address the disproportionate impact of COVID-19 on HCBS beneficiaries duallyeligible
for Medicare and Medicaid; and
- CMS should encourage states with MLTSS programs to leverage their MLTSS plan partners in the
distribution of these funds given MLTSS plans’ unique data streams and connections with the
HCBS provider community and beneficiaries.