On July 3, 2023, HCAF submitted comments to the Centers for Medicare & Medicaid Services (CMS) regarding the proposed rule, Medicaid Program; Ensuring Access to Medicaid Services, published in the Federal Register on May 3, 2023. According to CMS, the proposal takes a comprehensive approach to improving access to care, quality, and health outcomes, and better addressing health equity issues in the Medicaid program across fee-for-service (FFS), managed care delivery systems, and in home and community-based services (HCBS) programs.

HCAF expressed its support for various aspects of the proposal that would strengthen and improve Medicaid, including the establishment of grievance systems, advisory groups, reporting requirements, and promotion of payment rate transparency. HCAF expressed concern, though, about the proposal to allocate at least 80% of Medicaid payments for personal care services, homemaker services, and home health aide services to direct care workforce compensation.

"It cannot be overstated how important direct care workers are to Medicaid recipients in terms of providing essential care and maintaining dignity and independence among the elderly and individuals with disabilities," wrote HCAF Executive Director Bobby Lolley, RN. "We recognize the intention behind this provision, however, we strongly believe that CMS' uniform approach is flawed and fails to take into account the unique challenges that different states face."

Lolley stated that Florida faces challenges due to outdated reimbursement rates, inflation-induced increases in business costs, and the long-term effects of the COVID-19 pandemic. Additionally, he discussed the implementation of a $15 minimum wage by the Florida Legislature in 2022 for Medicaid direct care workers, resulting in an increase of 29.3% in payroll costs for employers. Meanwhile, the reimbursement rates for home health services and private duty nursing services have only increased by 3.33%. Lolley pointed out that home health aide reimbursement rates in Florida are among the lowest in the country, significantly lagging behind neighboring and other populous states.

HCAF designed an online advocacy portal that provided Medicaid providers and stakeholders with information about the proposal, talking points, a customizable comment template, and instructions for submitting comments. More than 2,000 comments were submitted in total.

HCAF also co-signed comments submitted by the National Association for Home Care & Hospice and the Home Care Association of America in addition to its own comments.

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