Concern:

Risk of Institutionalization: Under the proposed rules, individuals with severe cognitive or behavioral needs might fail to qualify for exceptions over 56 hours, increasing their risk of being institutionalized.

Recommended Solutions:

1 Use existing DD waiver assessments and Plans for Supports rather than nursing-oriented metrics.

2 Protect current authorizations by preventing automatic reductions without individualized health and safety assessments.

3 Establish clear appeal processes that maintain existing services during the reconsideration period.