Prepare Ye for HCBS Rule

Just because the final details aren’t in place doesn’t mean disability organizations can wait to prepare for the incoming changes that HCBS will bring.

The time to prepare is now.

While I don’t wear fur skins and eat locusts and honey, I travel all over the country meeting with CEOs and EDs of disability organizations, their leadership teams and representative staff teams, people with disabilities, families, and board members. Inevitably I bring up the topic of HCBS. Appreciating the genius they bring to the table, I am still amazed and more than concerned that knowledge of HCBS Final Rule and its implications are still relatively obscured and unknown.


Here’s a few verbatim comments that ao has heard:

“Our state hasn’t gotten an approved plan yet. Or maybe they did…?”

“Yes, I read something about it.”

“I don’t think it applies to us.”

(Shaking of head when asked if they knew about HCBS).

(In whispered tones: ) “I heard you aren’t safe unless you are over the $25 million mark…”


Leaders, it’s not okay to advance one more day in your organization without implementing a process of infusing awareness of what the federal government is aiming to put into place beginning March of 2019. There are plenty of informational resources out there. Type in “HCBS Final Rule” on Google, hit enter and a plethora of information, articles, powerpoints, and yes, even youtube videos are at your fingertips. Staff, people you serve, your Board, families and yes, even communities all need to know what is on your doorstep.


That’s just the beginning. The process of change for those organizations that operate CMS-reimbursable programs and services that are considered by CMS to be non-integrated and non-community based is complicated. It takes thought, preparation. Knowing about the Rule isn’t enough – organizations need to know how to implement the Rule. Just as you can’t put old wine into new wineskins, you can’t re-program old programs and old thinking into new. Let’s face it, in its day, sheltered workshops and large group homes were a good idea. They were considered back then a mark of progress, and necessary steps to get people with intellectual and developmental disabilities out of isolated homes and into a community. Those steps have been taken and it has brought us to a new precipice in time and practice.


Things to consider beyond the awareness include leveraging your key stakeholders in the process of change. Understanding how old attitudes by staff, people served, Board and families can disrupt the forward progression that survival demands – and how to effectively transform their passion into forward thinking attitudes is key. It means looking at new ways of doing things. Considering new partnerships and collaborations. Looking at infrastructure and physical plant and community through a new lens. Time. Internal processing of change in behaviors and in practices that support them.


Don’t wait for someone to lead you down this path because quite honestly, that might not ever happen. Take initiative. Begin the process of change even if all the details aren’t in place yet. Prepare ye. You’ll be in a far better position to manage change – and it’s a’coming – if you do.

August 16, 2016

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