Account for Unfunded Regulations

HCBS providers are unique as private businesses in that they can have unfunded government regulations placed upon them but little to no ability to adjust their cost of service to reflect increased expenses and increased quality of services. With over 95% of revenue coming from state and federal determined Medicaid reimbursement rates, costly mandates force providers to choose between innovative services, staff wages, serving individuals or simply keeping their doors open.

Unfunded regulations include:

  • Increases in Licensing Fees
  • Minimum Wage Increases
  • New staff fingerprinting and background studies (With providers facing nearly 60% turnover rates, the cost to bring on new employees can add up very quickly.)
  • Attestation and required follow up including structural changes to individual's homes
  • Positive Support Rule Annual Training
  • Billing Changes
  • Service Verification

ARRM's Legislative Solution

ARRM's 2019 Legislation will do two things:

1. Instruct the commissioner to adjust the disability waiver rate system to ensure that any new costs enacted by the legislature or that result from any new requirements imposed by the commissioner on providers are added to the rates generated by the disability waiver rate system.
2. For costs resulting from state or local government mandates a provider will have the ability to report the costs and request a rate add-on.


Sara Grafstrom
Director of Advocacy and Community Relations
651-291-1086 x. 8