Saving Wrentham and Hogan Alliance

09/03/2026

The Saving Wrentham and Hogan Alliance (SWHA) has been asked to comment on the growing discussion about installing cameras in group homes. After reviewing the issue carefully, our official position is neutral.

We recognize that cameras can play a role in transparency and accountability. They may help clarify what happened in common areas after an incident occurs, and they can support investigations when questions arise. Families often feel reassured knowing that some level of monitoring exists.

However, cameras have significant limitations that must be acknowledged honestly.

1. Cameras cannot be placed in bathrooms or bedrooms.
These are the areas where residents are most vulnerable and where the most serious incidents historically occur. Because cameras are prohibited in private spaces, they cannot capture or prevent abuse, neglect, or mistreatment that occurs out of view.

2. Cameras do not prevent abuse.
They are a documentation tool, not a prevention tool. Cameras cannot detect: intimidation, threats, coercion, neglect, emotional mistreatment, inappropriate physical contact in private areas

They also cannot intervene in real time.

3. Cameras can create a false sense of security.
When cameras are installed, there is a risk that policymakers and providers may present them as a comprehensive solution. They are not. Cameras do not replace: strong staffing ratios, active supervision, unannounced visit, robust Human Rights enforcement, transparent incidence reporting, and meaningful oversight.

4. Cameras must be part of a broader safety strategy.
If cameras are used, they should be accompanied by: clear policies, independent review, protections against misuse, strong Human Rights safeguards, and continued family access and involvement

Cameras alone cannot ensure safety.

SWHA is neutral on the use of cameras in group homes. We believe that our state needs a much broader safety strategy.
We support any measure that increases transparency, but we caution families, providers, and policymakers not to rely on cameras as a stand‑alone solution. Real safety requires comprehensive oversight, strong staffing, and a culture of accountability.

09/03/2026

Massachusetts made assurances to the Centers for Medicare and Medicaid Services (CMS) in its July 1, 2023 request for renewal of their intensive supports waiver.
Massachusetts promised CMS:
• annual Level of Care (LOC) reevaluations
• psychologist oversight
• validated assessment tools
• transparent documentation
Families received none of these.
The gap between the waiver and reality is a broken promise.

09/02/2026

A Waiver Cannot Work If Its Core Tool Is Missing
The shortened MASSCAP is central to the Massachusetts waiver’s Level of Care evaluation process.
But Massachusetts families never see it.
The Department of Developmental Services (DDS) does not provide it.
It is possible that the Canters for Medicare and Medicaid Services (CMS) never reviewed it.
A waiver cannot be effective when its foundational assessment tool is absent in practice.

09/01/2026

We have never seen a shortened MASSCAP, the assessment tool that Massachusetts DDS claims it uses annually to assess individual's needs and develop the person-centered plan. Did Centers for Medicare and Medicaid Services (CMS) approve the waiver without ever seeing the shortened MASSCAP?

Did CMS evaluate whether the tools are appropriate or clinically valid?
Massachusetts described a process, and perhaps CMS accepted it without verification.

08/31/2026

Massachusetts promised the Centers for Medicare and Medicaid(CMS) that they would use a shortened MASSCAP to assess needs and develop the person-centered plan. Has anyone ever seen a shortened MASSCAP? Can this tool assess communication needs?

Does the tool does not evaluate communication, AAC needs, OT/PT, sensory supports, or allied health services?
Is it a clinical assessment?
Can it determine what supports a person actually needs?
Did CMS approve a tool that is inadequate for its stated purpose?

08/30/2026

The Centers for Medicare and Medicaid Services (CMS) Approved a Massachusetts Tool No One Has Ever Seen. Massachusetts told CMS that the Department of Developmental Services (DDS) uses a “shortened version of the MASSCAP” every year to reevaluate Level of Care.
Families never receive this tool.
It is not published anywhere.
A core requirement of the waiver renewal is invisible in practice.

08/29/2026

If DDS were actually doing what the waiver promises…
Then the communication/allied health evaluation would come from:

Vineland‑III (communication domain)

ICAP (social/communication domain)

CCA (caregiver ability to support communication)

additional assessments (speech, OT, PT, behavioral)

The waiver explicitly says DDS will use:

“psychological or behavior assessments, additional functional and adaptive assessments, educational, health, mobility, safety, and risk assessments.”

That includes communication.

08/28/2026

Under both: 1915(c) waiver requirements, and Massachusetts’ own regulations,

DDS is responsible for determining what supports an individual needs to remain safely and successfully in the community.
That includes: communication supports, behavioral supports, OT/PT, sensory supports, assistive technology, caregiver training, environmental modifications

These are core Home and Community-Based Services (HCBS) domains.

08/27/2026

Massachusetts made assurances to the Centers for Medicare and Medicaid Services (CMS) in their July 1, 2023 request for renewal of their intensive supports waiver. The waiver application says level of care (LOC) is reevaluated annually — and whenever a participant’s needs change. But families rarely receive written LOC determinations or the shortened MASSCAPs that were promised yearly. Without data, there is no accountability. Massachusetts promised transparency. It delivered opacity.

08/27/2026

Here is the presentation from the July 2026 open board meeting of the Saving Wrentham and Hogan Alliance:

This presentation was given at the July 2026 open board meeting of ...