policy
ACAP Comment Letter on Self-Direction in MLTSS (HCBS-10)
October 5, 2017
To: Mathematica Policy Research
Re: ACAP Comments on HCBS-10 – Self-direction of services and supports among people receiving LTSS
through managed care organizations.
Sent via email to HCBSQualMeasures@mathematica-mpr.com.
The Association for Community Affiliated Plans (ACAP), is pleased to submit comments on quality measure
HCBS-10 – Self-direction of services and supports among people receiving LTSS through managed care
organizations. ACAP represents 61 not-for-profit community-based Safety Net Health Plans located in 29
states. Our member plans provide coverage to about seventeen million individuals enrolled in Medicaid,
Children’s Health Insurance Program (CHIP) and Medicare Advantage Dual-Eligible SNPs. Nationally, ACAP
plans serve almost half of all Medicaid managed care enrollees. Twenty-four of our plans operate managed
long-term services and supports (MLTSS) products, 24 are D-SNPs, and 14 of participate in the Financial
Alignment Demonstration, accounting for approximately 30 percent of all enrollment in the Demonstration.
Below are ACAP’s specific comments on this quality measure. Overall, ACAP supports this measure with
modifications.