Ohio Home and Community Based Services Coalition Submits Medicaid Rule Comments

Director Corcoran and the Ohio Department of Medicaid, thank you for allowing us to provide comment on OAC 5160-12-05, a rule that has been filed for its five-year rule review.

The Ohio Home and Community Based Services Coalition (OHCBSC) is a group of nearly 50 organizations and 10 self-advocates committed to protecting and expanding the HCBS system in Ohio. Our mission is to advocate for a strong home and community-based services and supports system that provides all Ohioans the opportunity to thrive and stay connected and engaged in our communities. A key component of this goal is advocating for increased reimbursement rates for providers, especially because this ensures that individuals have a meaningful choice to receive stable care in their homes and communities.

Today, OHCBSC is submitting comments addressing reimbursement rates in the HCBS system. The Medicaid program has become burdensome for community-based providers, making it difficult for providers to continue serving vulnerable populations. It is critical to reduce the burden providers face in the Medicaid program, ultimately ensuring access to HCBS for consumers and preventing costly institutional care.

As you know, COVID-19 has presented significant barriers for both providers and individuals in the HCBS system. Barriers within the HCBS system threaten older adults and individuals with disabilities, putting them at the higher risk for institutionalization. To prevent institutionalization of Ohio’s most at-risk individuals and expand transitions for those already institutionalized, we must address the root cause of our services system. Simply put, individuals cannot transition to or remain in their communities if the state does not invest in the workforce that makes these transitions possible.

Over the past 20 years, Medicaid reimbursement increases have been nearly non-existent for care at home. In 2020, providers' reimbursement rates are not sufficient to cover basic costs, much less additional PPE and precautions that protect at-risk individuals from COVID-19. The HCBS system cannot improve if it is not responsive to the needs of individuals and providers. To ensure that individuals have meaningful choice in their care, ODM must increase reimbursement rates, provide additional funding to offset pandemic-related costs, and increase access to PPE that keeps individuals and those that care for them safe.

As these proposed rules stand, they are not sustainable for the maintenance or growth of home and community-based services in Ohio. There must be consideration on how no proposed changes to increased rates or reduction in regulatory burden will affect providers both now and in the long term. Increasing these rates will, in turn, make care more available, reliable, and consistent for consumers. It’s clear that providers want to continue serving vulnerable Ohioans in their homes, but there must be changes in order to make the HCBS service industry sustainable.

Thank you for the opportunity to comment on OAC 5160-12-05. Feel free to reach out to Jordan Ballinger, Policy Director at Disability Rights Ohio, at should you have any questions regarding these comments. Thank you.


The Ohio Home and Community Based Services Coalition

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