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Dates and Deadlines
All states must submit to CMS a plan for transitioning their current HCBS system into compliance with the new rule by March 17, 2015. States submitting a 1915(c) waiver renewal or amendment before March 17, 2015 must include a transition plan in that submission. States then have 120 days from that submission date to submit a transition plan for the remainder of their HCBS system.
Arizona’s Medicaid system operates entirely through an 1115 waiver called the Arizona Health Care Cost Containment System. CMS has indicated that HCBS delivered through 1115 waivers must be compliant with the rule. Advocates are still awaiting guidance from CMS how they will implement and enforce this requirement.
State DocumentsBack to TOP
- Arizona HCBS homepage
- Clarifications and/or Modifications required for Initial Approval (CMIA): This letter notifies states that public comment, input and summary requirements are met, but CMS has identified issues that must be resolved in the Statewide Transition Plan (STP) prior to initial approval. CMS sent this letter to Arizona on November 25, 2015
- NEW Initial Approval with Milestones and a Resubmission Date. This letter is the communication CMS sends to the state notifying the state that public comment, input and summary requirements are met, the STP is sufficient, but systemic and/or site-specific assessments are not yet completed. The response to the state will vary dependent on whether the state has or has not identified settings that are presumed to have institutional characteristics and any information the state may wish CMS to consider under the heightened scrutiny process. September 6, 2017
After consideration of public comment, AHCCCS submitted its final Systemic Assessment and Transition Plan (linked below) to CMS for approval on September 30, 2015. AHCCCS will have 5 years to come into compliance with the rules under the Transition Plan. During the 5-year transition period, AHCCCS will work with a variety of stakeholders to implement the plan. Additionally, AHCCCS will work collaboratively with the contracted health plans to ensure providers are adequately oriented and trained on their respective roles and responsibilities in ensuring members have full access to the benefits of community living.
- CMS NOTICE LETTER
- COMMUNITY STAKEHOLDER MEETING NOTES
- COOLIDGE CAMPUS LETTER
- MEMBER AND PROVIDER SURVEYS
- HCBS RULES OVERVIEW
- PUBLIC COMMENT MATRIX
- FORUM COMMENT FORMS
- EMAIL COMMENTS (1-100)
- EMAIL COMMENTS (101-147)
- LETTER COMMENTS
- ACRONYMS AND DEFINITIONS
AHCCCS conducted a preliminary assessment of Arizona’s HCBS settings to determine its level of compliance, provide recommendations for identified variances, and outline a process for continuous monitoring. The assessment process included a review of statutes, rules, policies and contract language. AHCCCS has published its draft assessment of Arizona’s HCBS settings and the draft transition plan to seek public comment. The draft of Arizona’s Systemic Assessment and Transition Plan is linked below.
During the public comment period (Aug 1-31, 2015), AHCCCS will host a round of statewide community forums to walk through the draft assessment findings and draft transition plan and take public comment. Stakeholders may also submit comments directly to AHCCCS during this period. AHCCCS will review and consider all public comment received.
- Community Forum ScheduleCommunity Forum Schedule– Employment Services – August 28, 2015
- Community Forum Presentation
- Community Forum Presentation – Employment Services
- Community Forum Presentation – Spanish Version
Written and Email Comment Submissions
Stakeholders may also submit comments on Arizona’s Systemic Assessment and Transition Plan directly to AHCCCS during this period. AHCCCS will review and consider all public comment received.
The following questions are some items to consider when reviewing the assessments:
- Is the systemic assessment accurate?
- Does it contain the appropriate references to Arizona Revised Statutes, Arizona Administrative Code and AHCCCS and Managed Care Organization policies and contracts?
- Is the assessed compliance level finding reflective of the evidence provided?
The following questions are some items to consider when reviewing the transition plans:
- Does the remediation strategy directly address the compliance issue?
- Is the timeline for the remediation strategy appropriate and realistic?
- Is the proposed monitoring method the most effective way to ensure ongoing compliance?
To submit comments to AHCCCS or request a written copy of Arizona’s Systemic Assessment and Transition Plan:
- Email: HCBS@azahcccs.gov
- Mail: AHCCCS
c/o Office of Intergovernmental Relations
801 E. Jefferson Street, Mail Drop 4200
Phoenix, Arizona 85034
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