The Home Care Association of Florida (HCAF) has submitted comments to the Centers for Medicare & Medicaid Services (CMS) in support of Florida’s proposed amendment to its Managed Medical Assistance (MMA) Section 1115(a) waiver. The amendment would exempt permanently disabled Medicaid recipients from the standard 12-month eligibility redetermination requirement, helping prevent unnecessary coverage gaps for medically vulnerable individuals.

In its comments, HCAF emphasized that for patients receiving home- and community-based services, even brief lapses in Medicaid eligibility can result in disrupted care, increased hospitalizations, caregiver strain, and a greater risk of institutional placement. Home health agencies experience these disruptions firsthand when services are paused or authorizations are delayed due to procedural redeterminations.

HCAF supports the amendment because it promotes continuity of care without expanding Medicaid eligibility or weakening program integrity. Under the proposal, coverage would continue during redetermination unless there is a material change in disability or financial status, preserving safeguards while reducing avoidable administrative churn.

HCAF also highlighted that the amendment aligns with Florida’s legislative direction and the Agency for Health Care Administration’s (AHCA) goal of maintaining access to cost-effective care in the home for permanently disabled individuals.

As part of its submission, HCAF encouraged clear guidance for families and providers to ensure services are not inappropriately interrupted during redetermination periods and urged coordination among state agencies, managed care plans, and providers.

HCAF will continue monitoring CMS’ review of the amendment and will keep members informed of developments affecting Medicaid coverage stability and access to home-based care.

Click here to read HCAF’s full comments and recommendations to CMS.