There has been a significant focus on participation levels as a critical yardstick in measuring the viability and success of the program. While higher participation generally does make it easier to obtain a reasonable spread of risk necessary to sustain the program, it should be made clear that it is the mix of individuals with different risk characteristics enrolled in the program at any one time, and not participation alone, that is the key to long-term sustainability. High participation from only higher-risk individuals will threaten the program.
Key factors influencing participation are affordability and marketing.
The premium levels must be affordable, competitive with what is available in the private longterm care insurance market, and of good value to consumers. But the CLASS program design includes features that increase adverse selection and result in relatively unaffordable premiums.
A strong marketing program would significantly increase participation and aid in obtaining a reasonable spread of risk. In addition, it would encourage individuals to plan for their future long-term care needs—and getting people to plan for their future LTC needs could help reduce pressure on the government, which currently pays for a majority of long-term care.
A sustainable voluntary program will have provisions to address many of the adverse selection concerns I have outlined. On behalf of the Academy, I offer the following recommendations for modifying the CLASS program: 
An actively-at-work definition with a minimum requirement of 20 to 30 hours of scheduled work or a comparable requirement;
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