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NCD Recommendations to Long Term Care Commission

Wednesday, July 3, 2013

July 3, 2013

Bruce A. Chernof, MD
President and Chief Executive Officer
The SCAN Foundation
3800 Kilroy Airport Way
Suite 400
Long Beach, CA 90814

Dear Dr. Chernof,

I am writing to you in your capacity as Chair of the Federal Commission on Long-Term Care. The National Council on Disability (NCD) is an independent federal agency required by its authorizing statute to advise Congress and the Administration regarding laws and issues that affect people with disabilities. NCD has published numerous reports pertaining to long-term services and supports, which can be found at long-term services and support.

NCD has long been concerned about (a) the lack of a coherent national long-term services and supports (LTSS) public policy for all people with disabilities; (b) the fragmented nature of service and support delivery systems, with uneven access to LTSS; and (c) no single entry point at a community level exists for individuals with disabilities and seniors to learn about and access service and support options, nor is there an integrated delivery system to provide portability across states. No single federal program, federal agency, or Congressional committee is charged with the responsibility for the management, funding, and oversight of LTSS.

The impending wave of aging baby boomers, increasing life expectancy, and rising disability rates in people under 65 will significantly increase the demand for LTSS in the coming decades. With the changing demographics of the United States, it is imperative that we explore the possibilities of a universal approach to the design and financing of LTSS.

America should have a coherent and comprehensive framework for its LTSS policies, programs, and funding. NCD offers the following recommendations:

  • Decouple eligibility for Home- and Community-Based Services (HCBS) under an HCBS waiver from a determination of nursing home eligibility. Remove the institutional bias in the Medicaid program to give Medicaid beneficiaries greater choice in where they live and how financial assistance is provided to cover a range of LTSS.
  • Increase support for families and significant others in their role as informal and unpaid caregivers.
  • Improve the supply, retention, and performance of direct support workers to meet increasing demand. Funding should be authorized for collaborative demonstration projects between the U.S. Departments of Labor and Health and Human Services that promote collaboration between community colleges and disability-related organizations to develop a high-quality set of competencies to be taught in a new support worker certificate program that expands supplies of quality workers to meet market demand in home- and community-based settings.
  • Mandate coordination and collaboration among federal agencies to align public policy and transform infrastructure to be responsive to consumer needs and preferences for a comprehensive system of LTSS.

I understand that the Commission is in the midst of producing a report and planning public meetings. NCD is available to provide you and the Commission with advice and assistance pertaining to these and other issues of importance to people with disabilities and welcomes any inquiries. Please contact NCD’s General Counsel and Director of Policy, Joan Durocher, at or at (202) 272-2004.


Jeff Rosen

CC:  Henry Claypool

NCD Sends Recommendations to Long Term Care Commission

An official website of the National Council on Disability