The Interested Parties Advisory Group (IPAG) requirement, established under the Medicaid Access Rule, instructs states to establish a work group to advise on the adequacy of rates for direct care workers who provide home and community-based services (HCBS) for people with disabilities. States must establish and begin convening IPAGs by July 2026.
This issue brief prioritizes strategies to help states implement IPAGs in ways that advance the Access Rule’s core objective: ensuring meaningful access to HCBS. By centering the experiences and needs of people with disabilities, states can also support more transparent and responsive rate-setting processes. In doing so, they can help secure adequate wages and develop strategies to strengthen the direct care workforce that supports people who use HCBS.
To inform this issue brief we conducted one-hour interviews with representatives from four organizations, using a consistent set of questions to guide each conversation. The organizations interviewed included consumer and workforce advocacy groups, provider associations, and labor organizations that represent the direct care workforce.
These interviews focused on understanding the current landscape of the direct care workforce, drawing lessons from other advisory groups, and identifying best practices to strengthen the influence of these stakeholder groups – particularly in shaping rate-setting decisions with buy-in from all of the key rate-setting partners. We also hosted a convening with participants from state agencies and advocacy organizations invested in strengthening the direct care workforce to promote improved access to long-term services and supports (LTSS).
Additionally, incorporated perspectives from select organizational comments submitted during the Access Rule public comment period that both reflected and prioritized community integration, and drew on state laws, regulations, policies, and practices relevant to community input on rate setting for various types of HCBS. These qualitative activities, alongside our resource review, directly informed our recommendations for effective implementation of the IPAG.