24. Plaintiffs bring this case on behalf of themselves as well as on behalf of a proposed class consisting of all Idaho Medicaid participants currently receiving Residential Habilitation Services in a Supported Living Environment.  25. Plaintiffs believe that the proposed class consists of at least hundreds, and likely thousands of individuals. Such a group is too numerous for joinder of all members to be practicable.  26. This case presents common questions of law and fact including whether the reimbursement rate cuts will cause service reductions, whether such service reductions will impact quality of quantity of care, whether proper notice was provided, whether an opportunity to appeal the decision was provided, whether such notice and opportunity was required as a matter of law, whether rate cuts will lead directly or indirectly to institutionalization of some members of the class, and whether requiring maintenance of existing rates constitutes a fundamental change in Idaho’s Medicaid program.  27. The named Plaintiffs are typical of the members of the proposed class in that their claims arise from the same facts and course of conduct by Defendants, and thus are typical of the claims of the putative class.  28. The named Plaintiffs have no conflicts of interest with other members of the class, have retained counsel adequate to bring this action, and because of their shared interests will fairly and adequately protect the interests of the class.  31. Plaintiffs incorporate the preceding paragraphs as if fully set forth herein.  32. By operating the state Medicaid program in a way that it forces some members of the putative class into institutions, Defendants are violating the integration mandate of the ADA as set out in implementing regulations.  32. Because Plaintiffs and the putative class have a property interest in continued receipt of Medicaid benefits, they are entitled to notice and an opportunity to be heard prior to cessation or reduction of those benefits, pursuant to the XIVth Amendment to the United States Constitution.  33. In addition to their Constitutional rights to due process of law, Plaintiffs and the putative class have a right based in federal statutes and regulations to notice and an opportunity to be heard prior to reductions in their benefits pursuant to 42 U.S.C. §1396a(a)(3).  34. Defendants were obligated to but have not provided notice and an opportunity to be heard, despite that, while acting under color of state law, they are reducing the benefits and services that Plaintiffs and the putative class will receive on and after February 1, 2016.  36. Plaintiffs incorporate the preceding paragraphs as if fully set forth herein.  37. Plaintiffs and the members of the putative class, by definition, qualify for institutional care in Idaho’s Medicaid program. Medicaid participants may only qualify to receive ResHab services if they face institutionalization “in the near future” in the absence of intensive community supports.  38. By precipitously reducing ResHab service rates, causing the termination of services for some, and the necessary reduction of services for most or all ResHab recipients, the Defendants will force some participants into institutional care. This will occur either because participants and their guardians will seek institutional care in the absence of available community supports, or because participants will be involuntarily placed into hospitals or jails as a direct and proximate result of the reduction or loss of community services.  Denial of Due Process of Law 42 U.S.C. §1983; 42 U.S.C. §1396a(a)(3)  VIOLATION OF THE AMERICANS WITH DISABILTIES ACT; 42 USC §12132 