Thank you for the opportunity to provide comment on behalf of our one million members on enhanced home- and community-based services (HCBS) funding through the American Rescue Plan Act (ARPA). AARP Virginia believes the additional federal dollars can greatly expand on the current work your department is doing to serve more Virginians in the community. We welcome the opportunity to work with DMAS to enhance the work already in progress.

Specifically, these funds could be used to:

• Support individuals in community-based settings, and their caregivers, in accessing COVID-19 vaccines, including help with scheduling and transportation to appointments, opportunities for in-home vaccination, and providing personal protective equipment.

• Create or expand nursing facility transition programs, to allow beneficiaries to transition out of facility-based care and back to their community. The temporary funding provided during the enhanced Federal Medicaid Assistance Percentages (FMAP) term can include intensive case management services for individuals currently residing in nursing homes, or for those at risk of institutionalization, so that they may return or remain in the community.

• Provide temporary funding for expenses to maintain or return individuals to community-based care in their own home or a HCBS setting.

• Expand funding for programs to allow HCBS beneficiaries to physically adapt or modify their homes to accommodate their functional limitations and to access assistive technology software, equipment, or products that can help them improve, increase, or maintain specific functional capabilities.

• Increase Virginia’s capacity to assess the needs of family caregivers who care for their loved ones, including identifying at-risk family caregivers before they burn out or compromise their own physical and mental health. Examples include funding for the development/adaptation of family caregiver assessments modules, support group start-ups, needed supplies and equipment for family caregivers providing care, and paying family caregivers to provide care. Develop or expand funding for respite care services to allow family caregivers to take a break from their caregiving duties. Respite care services should be offered in a wide range of settings and be available to family caregivers who would not otherwise qualify for publicly funded respite services.

• Increase access to family caregiver services to delay or decrease the likelihood of a loved one’s need to seek care in a long-term care facility, including education and training, counseling, support groups, and legal consultations.

• Provide a temporary Medicaid HCBS provider rate increase to fund wage and benefit pass-throughs to direct care and nursing staff, with a process to ensure provider accountability.

• Expand Aging and Disability Resource Center No Wrong Door Services, to assist beneficiaries in navigating and obtaining the HCBS needed to age in place.

• Expand funding for additional services that support HCBS, such as personal care supports, conflict-free care management, adult day services, and other caregiver support services. Services should be offered in a range of settings, including supportive housing and adult day centers.

• Implement new eligibility policies and/or procedures, such as expediting eligibility for HCBS (subject to CMS approval).

• Expand provider capacity for mental health and substance use disorders, as well as expanded rehabilitation services.

Finally, we thank you for engaging the public and community partners as you consider how to apply the FMAP increase. Virginia has a tremendous opportunity to leverage federal dollars to respond to our long-term care needs and improve the lives of many older Virginians. Please reach out if AARP Virginia can be helpful in any way in responding to the Centers for Medicare & Medicaid Services.