Ohio is making several significant Medicaid and HCBS changes at roughly the same time.
Each has its own stated purpose.
But people with disabilities and their families don’t experience policies one at a time.
They experience the combined effect.
Here is what has happened:
• March 25, 2026: HB 795, the SHIELD Act, was introduced as a Medicaid program-integrity/verification bill. It later underwent substantial changes in the House Medicaid Committee. (Ohio House of Representatives)
• During that process, a substitute version included a broad proposal restricting Medicaid payment to family caregivers. After extensive testimony from disabled Ohioans, families and advocates, that provision was removed. (The Statehouse News Bureau)
• May 14, 2026: Ohio Medicaid began a six-month moratorium on new enrollment for multiple home- and community-based provider types—including waiver individuals and organizations, private-duty nurses, personal-care aides and home-care attendants. Existing enrolled providers may continue operating. (Maximus)
• Importantly, the moratorium does not mean an existing agency cannot hire workers. Ohio rules define a DSP as an employee of an agency provider, while an independent provider is self-employed and separately certified. So a prospective worker may potentially enter the workforce through an existing agency even though the pathway to newly enroll as an independent waiver provider is temporarily closed. (Ohio Laws)
• Major Medicaid program-integrity provisions ultimately moved through SB 315, which passed June 10, was signed July 7, and takes effect October 6, 2026. The final law does not contain the proposed family-caregiver ban. (Ohio Legislature)
• At the same time, Ohio DODD is implementing Waiver Modernization and interRAI and developing future acuity-based reimbursement. DODD says Ohio-specific rates will eventually use information from interRAI assessments and previous service utilization. (Cloudinary)
That raises an important question:
Who is measuring the cumulative effect of all these changes on actual HCBS capacity?
For example:
• How many authorized hours are actually being delivered?
• How many remain unstaffed?
• Is independent-provider capacity declining during the moratorium?
• Are agencies actually absorbing workers who otherwise would have become independent providers?
• Does that differ between rural and urban Ohio?
• How long does it take to find a provider with the competency an individual actually requires?
• When providers cannot be found, who fills the hours?
• How much care shifts to paid family caregivers?
• How much shifts to unpaid family caregivers?
• How much simply becomes unmet need?
• Are people reducing community activities because support is unavailable?
• Are families privately purchasing resources that Medicaid or waiver programs do not provide?
• Are medically complex or unusual cases requiring disproportionate exceptions and appeals?
And there is another important measurement issue:
If future funding is informed partly by previous service utilization, what happens when previous utilization was already constrained by provider shortages?
A person might need 80 hours, be authorized for 80, receive only 45 because nobody could staff the remaining hours, and have family provide the rest.
Claims may show 45.
Need was still 80.
That is why historical utilization must be interpreted alongside provider availability, authorized-but-undelivered services and family substitution.
None of this proves these policies were intentionally designed to work together or that any particular policy will produce a harmful result.
It does mean their combined effects should be measured.
Fraud prevention can be important.
Standardized assessment can be useful.
Better reimbursement can be useful.
Provider oversight can be important.
But individually reasonable policies can still interact in ways that create unintended consequences.
So before—and during—major HCBS modernization, Ohio should be able to answer:
What happened to provider capacity?
What happened to delivered services?
What happened to family substitution?
What happened to unmet need?
What happened to community participation?
And for whom did the system get better—or worse?
Because people don’t live inside policy silos.
They live at the intersection of all of them.
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