2. ALWPP should not impose new onerous standards that limit provider participation and restrict consumer choice.

3 ALWPP should be designed to allow easy participation by all RCFEs and especially small providers which frequently provide care for patients with wheelchairs or with dementia who could wander in cities where most large RCFEs are not licensed to accommodate this type of patient.

4. ALWPP should only require nurses for participants with care conditions currently prohibited (g-tubes, i.v's, tracheotomies, ventilators, etc.) in RCFE settings.

5. ALWPP should not create an unfunded mandate. ALWPP should incorporate a tiered base reimbursement rate (based on local market conditions) and allow providers to bill the state separately for patients who require nursing services. This approach would encourage provider participation by allowing RCFEs to know their profit margin before participating with ALWPP.

6. ALWPP should not mandate private rooms when the reimbursement rates fail to reach market rate for private rooms for most RCFEs in pivotal (Los Angeles) pilot program sites areas.

7. ALWPP participants should be allowed to use their medi-cal dollars to seek out shared or private rooms in the marketplace and not be restricted to only non-profit or low cost providers.

8. All Olmstead measures, like ALWPP, should be cost efficient and designed so that medi-cal cost savings which involve the use of existing medi-cal dollars (nursing home transition) could be used to offset expenses associated with other measures that involve new dollars (aging in place).

9. ALWPP should incorporate sensible aging in place measures that do not obligate the state to upgrade RCFE residents in shared rooms to private rooms once they run out of money.

10. ALWPP should be designed to facilitate participation by a large number of RCFE providers and not create unnecessary bottlenecks for nursing home transition patients who choose to transfer to RCFE settings. Nursing home transition does not involve new medi-cal dollars and, eventually, could involve tens of thousands of participants.

11. The distinct ALWPP components--RCFE and public housing—and their reimbursement rates, etc. should be treated separately since the nature of these settings and their operating expenses are in no way related.

12. Once fair, tiered reimbursement rates based on local market conditions have been developed, all RCFEs should be notified directly about ALWPP and invited to participate.

13. The Department of Social Services which licenses RCFEs should be more involved in developing Olmstead policy related to these settings.

14. All Olmstead public policy, including ALWPP, should be transparent, open and allow for significant stakeholder contribution.