I do not believe that establishing a soft cap of 56 hours per week reflects sound person-centered planning, because individuals do not all have the same level of need. Some individuals require fewer hours of support, while others have significantly greater medical, behavioral, functional, or safety needs that require support beyond 56 hours per week.

Applying a 56-hour soft cap risks reducing necessary services for individuals whose assessed needs exceed that threshold. In many cases, family members are either unavailable, unable, or not physically capable of providing the additional care required once authorized service hours have been exhausted. A standardized cap does not adequately account for these individual circumstances.

Reducing services based primarily on a predetermined weekly threshold rather than an individualized assessment of need may also increase the risk of preventable hospitalization, caregiver burnout, institutionalization, or placement in a nursing or long-term care facility. This would be contrary to the goal of supporting individuals to remain safely and successfully in their homes and communities whenever appropriate.

Home- and community-based services are intended to promote independence, stability, community integration, and the ability of individuals to receive necessary supports in the least restrictive setting. Individuals should therefore receive services based on their documented needs, level of functioning, risks, natural supports, and individualized plan of care—not primarily on a uniform number of hours.

For these reasons, I strongly recommend that the proposed 56-hour soft cap not be implemented according to the proposed timeline. Instead, service hours should continue to be determined through individualized assessments, with appropriate clinical and functional justification for individuals who require more than 56 hours of support per week.

Any utilization-management process should preserve the ability to authorize additional hours when the individual's documented needs demonstrate that those services are medically and functionally necessary to maintain health, safety, independence, and continued community living.