The 10 percent enhanced FMAP for HCBS comes at a time when additional funds are critically needed.  Unfortunately, HCBS providers have not benefited from an increase payment to offset increased cost associated with the COVID response or a corresponding loss in revenue.  This means that HCBS providers have not had an opportunity to invest in infrastructure needs, such as telehealth or other efficiencies that will better position the market for future responses to public health emergencies. 

Because of the limited time ARP HCBS enhanced FMAP funds are available there isn’t an opportunity to invest in long term projects or changes that will incur ongoing general revenue cost after the HCBS enhanced FMAP is no longer available. Therefore, we recommend that Virginia state policy makers

1. Pursue a strategy that will maximize reimbursement for personal care providers, allowing them to hire and train staff to meet critical needs in local communities.
2. The rate increases should be retroactive to April 1, 2021
3. The directed payments provisions of 42 C.F.R. § 438.6(c) should be invoked to ensure that increased funds are indeed distributed to managed care and passed along to personal care providers