26.  Definition of Class.  The class consists of all individuals who:  a. Are  Medicaid  recipients  with  an intellectual or developmental disability;   b. Need an institutional level of care provided in a Medicaid-certified ICF in the  State of Washington; and   c. Qualify for and desire DDA home and community-based habilitative services  which they are not receiving.    27.  Size of Class.  The class of Medicaid recipients who qualify for, have requested,  and are not receiving home and community-based services administered by DDA is expected to  be so numerous that joinder of all members is impracticable.  Defendants have identified as  many as ninety-one DDA clients as waiting for residential habilitative services in the  community, while only a handful of these individuals have been offered these services.   45.  In 2013, DSHS retained a private consultant, Navigant Healthcare, to conduct an  independent review of its supported living program.  Navigant’s November 11, 2013 report  documented that there was a waitlist for supported living services.  It went on to explain, “DDA  manages the wait list to prioritize those with the highest levels of need. Due to budget  constraints, only individuals whose needs fall into levels 4 through 6 are generally admitted into  the program.”      46.  Navigant interviewed three supported living providers regarding DDA rate setting  and documented the following:   “Providers also discussed the challenge they face due to high staff turnover. They  associated low reimbursement rates with an inability to pay competitive wages  and high staff turnover. Specifically, the hourly ISS [(Instruction and Support  Services)] rates have been decreasing since 2009 while the Washington State  minimum wage has increased. In addition, the high turnover puts pressure on their  training budgets as they must train all new staff.”   62.  Plaintiffs re-allege the paragraphs above.   63.  Plaintiffs and the putative class are all “qualified individuals with a disability”  within the meaning of 42 U.S.C. § 12131(2).  Plaintiff and class members have not been  provided services they would need to live in an integrated setting in the community.     67.  Plaintiffs re-allege the paragraphs above.   68.  Plaintiffs and putative class members are qualified individuals with disabilities  under Section 504 of the Rehabilitation Act, 29 U.S.C. § 794 (a).  Defendants’ agencies, HCA  and DSHS, receive federal financial assistance.   69.  Defendants violate Section 504 of the Rehabilitation Act and its implementing  regulations by denying Plaintiffs and putative class members access to integrated community- based programs appropriate to meet their needs, thereby requiring that Plaintiffs and putative  class members be confined in segregated institutions in order to receive the services that they  need, or suffer risk of institutionalization.   SECTION 504 OF THE REHABILITATION ACT   TITLE XIX OF THE SOCIAL SECURITY ACT   WITH DISABILITIES ACT  