The Home Care Association of Florida (HCAF) submitted formal comments to the Centers for Medicare & Medicaid Services (CMS) in support of Florida’s proposed amendment to the Managed Medical Assistance (MMA) Section 1115 Demonstration. The amendment is necessary to fully implement SB 1156 (2025) — legislation HCAF championed to strengthen Florida’s Family Home Health Aide (FHHA) program for medically fragile children.

The proposed amendment would:

• Exclude FHHA wages from Medicaid eligibility determinations, ensuring that families do not risk losing coverage because a parent or relative is trained and compensated to provide necessary care.
• Authorize Private Duty Nursing (PDN) specialty providers to train, employ, and supervise FHHAs — significantly expanding program capacity and access to care, particularly in rural and underserved areas.

Built-in Program Safeguards

SB 1156 established strong guardrails to ensure quality and patient safety, including:

• A minimum of 76 hours of training combining classroom instruction, clinical supervision, child-specific education, and competency checks.
• Oversight and quality monitoring by licensed agencies, including satisfaction surveys, incident tracking, and hospitalization data review.
• Utilization limits of 12 hours per day and 40 hours per week, with exceptions allowed when medically necessary.

Aligning With Waiver Goals

The amendment supports the goals of the MMA 1115 Demonstration by:

• Expanding access to home- and community-based services (HCBS) for children with complex medical needs.
• Reducing unnecessary institutionalization and avoidable hospitalizations.
• Addressing workforce shortages through a structured model that integrates trained family caregivers under agency oversight.

“Without CMS approval, the reforms enacted in SB 1156 cannot be fully realized,” wrote Denise Bellville, RN, Executive Director of HCAF. “These changes will strengthen access to care, empower families, and ensure medically fragile children can remain safely at home with trained caregivers under professional oversight.”

HCAF appreciates CMS’s consideration and stands ready to serve as a resource to support the review and implementation of this critical waiver amendment.

Read HCAF’s full comments here.