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eligibility are reimbursed by the federal government at about 80%, with a cap. Currently state dollars are used to fund the non federal share of administration. In 1998, the County Commissioners Association ofND recommended that Healthy Steps become a county administered program and they agreed to pay the 20% non-federal share if a structure could be established to assure that this program did not become a fully unfunded mandate to the counties. The advantages of local administration of Healthy Steps are: First, it establishes a local program presence throughout the state, broadens program ownership, understanding and expertise throughout the state. Secondly it would improve program integration between Medicaid/Healthy Steps and other programs that serve low income families, i.e. food stamps, child care assistance and energy assistance. The disadvantages of local administration of Healthy Steps are that it would require more training and may generate more inconsistency in policy application. It would require a strategy to assure that local costs are appropriately reimbursed or a funding partnership is formally established between NDDHS/counties to prevent unfunded mandate. It may be more costly. Resolution Adopted in 2004 by Cass County Regarding Administration of Healthy Steps program 2004 Administration of Healthy Steps Because county social services administers eligibility for a range of financial support programs to low income individuals and families and the Healthy Steps Program is similar to other publicly funded programs, Cass County Social Services support local administration of the Healthy Steps Program if administrative reimbursement is provided. Home and Community Based Services for low income elderly/disabled Home and Community Based Services for the Elderly and Disabled are a network of in- home care programs and services that have been coordinated through a county administered case management system for low income individuals since the early 1980's. HCBS includes SPED, Expanded SPED, Medicaid Wavered, and county funded services. In 2003 two major program changes occurred. First, because of limited funding, the SPED program was frozen so that no new clients were served. This resulted in a significant referral pattern decline which carried over into 2004. In addition, there has been a major decrease in the number of direct service providers (QSP's) following the freeze partly because of lack of stable funding and because of limited reimbursement increases over the last six years. Secondly, income and asset tests were lowered while significantly increasing eligibility requirements. Finally, limits on the number of hours of services available and the definitions of services have resulted in additional HCBS