A Comparative Analysis of State Implementation of the Community First Choice Program

The Patient Protection and Affordable Care Act included Community First Choice (CFC), a new optional Medicaid home and community-based services (HCBS) state plan benefit which states could adopt. Through the CFC program, states can provide expanded home and community-based attendant services and supports to older adults and persons with disabilities. A benefit of CFC is that states receive a higher federal match rate than other HCBS programs. Thus far, eights states have adopted CFC. This comparative case study analysis examines state-level implementation of CFC to identify what facilitated implementation and what created challenges. The results suggest that consulting with the Centers for Medicare and Medicaid Services facilitated implementation while existing programs, insufficient engagement with stakeholders, aggressive timelines, and limited staff resources presented challenges. Based on these findings, states may want to consider how they approach implementing expansions or enhancements to HCBS benefits under the American Rescue Plan Act.