CMS proposed sweeping changes to state Medicaid programs through proposed rule-making: Medicaid Program; Ensuring Access to Medicaid Services CMS 2442-P. LeadingAge broadly supports the intent of the rule to improve access to and quality of services to participants. To achieve these goals, CMS proposes to increase transparency in rate comparisons and waiting lists, and development of additional administrative functions to promote participant wellbeing. While LeadingAge supports the proposals and intent, there are concerns with states’ abilities to operationalize the objectives in the proposed timelines with existing unwinding complexities coupled with limited available funds, time, and state staff. The most problematic piece of the proposal would require 80% of Medicaid funds paid for homemaker, home health, and personal care services (delivered under 1915 and 1115 authorities) to be directed to direct care staff compensation. CMS does not include adequate data to support their proposal, nor do they assess the impact on the provider community. LeadingAge has heard from many members that this threshold is untenable. If you’re considering preparing comments, here is a comment tip guide that contains LeadingAge’s thoughts. If you have questions about the rule, or comment composition, please reach out to Kylee Childs.