Last Chance to Comment On and Improve the In Home Supports (IHS) waiver – Comments Due WEDNESDAY

The state is finalizing changes to the IHS waiver and it’s critical that families and providers share their experiences and concerns during the formal comment period ending this Wednesday April 15, 2020.  Comments submitted now will be shared in the waiver application and provided to the US Center for Medicare and Medicaid Services which approves the waiver.

If you attended a listening session or submitted comments before March 16, you must share them again so that they are considered in the formal comment process.

Send comments to

Comments must be submitted by NOON (12:00 pm) on Wednesday, April 15, 2020.

Waiver Presentation:

Draft waiver:

The state addressed many of the concerns in the earlier public comment sessions by expanding the work of direct support professionals, introducing new methods of participation to support individuals to participate in the Participant Managed and Directed Services (PDMS) model, raising the cap on respite services, and adding several new services.

Some of the remaining concerns include:

  1. The cap is too low.

In the current waiver, the maximum budget is $30,000 per family per year. This has been raised to $35,000.  However, this is still too low for families with the highest needs.  The cost to serve one of these children at Cedarcrest, the state’s only ICF/DD facility is over $100,000 more per child.

  1. Choice of case manager must be protected

The state must ensure that families are given true freedom to choose an independent case manager and all case managers, whether employed by the area agencies or independent, are held to the same high standards.

  1. Public comment period is too short, given the circumstances.

While the state is providing 30 days of comment, with the current COVID-19 crisis, this is not sufficient. BDS did not clearly communicate that comments submitted in the earlier listening sessions would not be included in the formal comment process.

  1. Need to ensure consistency across the state

The Bureau of Developmental Services must ensure that the waiver is implemented consistently across the state.

  1. Family input and experiences must be prioritized

The state must prioritize the experiences of families as it implements the new waiver.

Send your comments and concerns as soon as possible.  Send comments to

Comments must be submitted by NOON (12:00 pm) on Wednesday, April 15, 2020.


Disability Rights Center – New Hampshire is a statewide non-profit organization dedicated to eliminating barriers for people with disabilities across New Hampshire. DRC is the federally designated protection and advocacy agency for New Hampshire and has authority under federal law to conduct investigations in cases of probable abuse or neglect.

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