Committee on Human Services - 09/09/26
Provider Revalidation and Continuity of Care for Individuals with Disabilities
Waiver Case Management System and Reforms
Full Document Analysis
Votes (3)
Impacts of Provider Revalidation and Authorization Delays on Disability Services
Several individuals testified about significant disruptions caused by DHS's revalidation process and the authorization contractor, Eccentra. Key issues included delays in authorization for EIDBI treatment impacting 1,000 children, financial instability for autism providers, critical nursing service authorization delays leading to severe health crises for clients, and inaccuracies in DHS's provider data systems leading to unpaid services and staff turnover. Witnesses advocated for immediate continuity of care, improved efficiency, and accountability from DHS and its contractors.
DHS Update on Revalidation and Continuity of Care Reforms
Commissioner Connelly presented DHS's perspective on the revalidation process, emphasizing federal mandates and the unprecedented scale of the effort. DHS detailed measures taken to support providers, reported on revalidation progress (3,600 providers revalidated, 1,500 appeals completed), and acknowledged documentation challenges and CMS scrutiny. The department outlined rebalancing efforts by allocating more staff to regular provider enrollment and hiring new personnel. The Commissioner also discussed continuity of care reforms from the 2026 legislative session, including new requirements for providers, lead agencies, and DHS to ensure seamless transitions, and provided an update on the housing support grant program.
County Perspective on Revalidation and Contracted Case Management
County representatives discussed their dual role in revalidation (supporting providers and being providers themselves), acknowledging frustrations but also improvements in DHS communication. They emphasized the foundational importance of case management and detailed reasons for utilizing contracted case management, including budget flexibility, culturally specific expertise, and managing clients outside their county of financial responsibility. The discussion highlighted the complexity of measuring case manager hours and the current unsustainability of waiver case management rates, calling for the newly established advisory working group and rate evaluation to find long-term solutions.
Notable Quotes (13)
After eight months of work, we now still only have twothirds of the autism provider locations being revalidated for authorized coverage of medically necessary EIDBI treatment. But once that hard work was completed, the families and providers have now been surprised and frustrated to discover that the state's authorization contractor, Eentra, was now failing to authorize the treatment of 1,000 children, which is onethird of the entire group of children who receive TERA fee for service coverage of EIDBI in the state of Minnesota.
The assessor and appeal judge stated that since he did not have status seizures in the past year that he cannot be given the code 03 on call medical. This is what is very troubling and wrong. Caregivers have to be ready if in case a seizure o o o o o o o o o o o o o o o o o o o o o o o o o o o o o o o o o o o o o o o o occurs and follow the protocol at any time. DHS is rewarding a medical crisis rather than prevention in this case.
An authorization delay honestly almost cost me my life this year. I was assessed as needing and approved for private duty nursing services back in November of 2024. These services were not optional. They were determined necessary because I have significant medical needs requiring ongoing management within my home um and the community. But being approved for nursing and actually receiving those nursing services have been two very different stories.
We have repeatedly been asked to submit the same information because data contained within the DHS system does not appear to match the information providers enter and maintain. We have gone 90 days without payment for many clients at affected locations. Even with one site approved, we do not anticipate anticipate payments until October.
As a nurse, my responsibility is not only to respondse when the crisis happens. My responsibility is to prevent crisis whenever is possible. Our client deserve care that are safe, timely and com compassionate and individualized. I strong believe that iced nursing staffing is essential. It is not luxury and it's not option to maintain the safety and quality of our clients.
I want to start a little off script and just say I think building upon what the chair just said, DHS is in a very difficult moment as we've heard that you are. So please know that we heard you and that our mission and this is on my my badge right now is to help people live their healthiest and fullest lives in community. And I heard that from you all today. We are here. We exist to do that in partnership with you.
The total number of providers out of the uh roughly 5,800 that were revalidated um total revalidated providers to date is about almost 3600. So we have a majority who are revalidated. A little over 1500 are still in appeal. uh excuse me those appeals are completed. So of the 30 uh the 3587 1,500 have had their appeals completed. They are revalidated. Remaining in Q in the process are a little under 1,200 providers and we are continuing to work through through those.
These reforms, uh, create new requirements for the state, the lead agencies, and providers themselves to, uh, ensure continuity of service when there is an interruption in care. It could be for a program integrity reason or for other reasons. Um, but for all of the above, there are new requirements in place.
I think one of the complications here and complexities with nursing services is that fundamentally nursing services is paid for um, under our state plan. Uh there are some unique situations under waiverss where the rate can be modified to account for um RN or LPN duties. Um but under the state plan, those services can be authorized um a little bit differently. Those usually happen they they're authorized typically through the homeare nursing agency. Um and then they go through the prior authorization process and get delivered by either a homeare nursing service or a skilled nurse visit.
I would say something halfway between that is the uh the waiver case management working group. Um I think because of all the parties that will be involved in that, we can come up with some recommendations and I believe that finishes at September 2027 is the report. So that actually some of that work um will be coming up uh will help us inform the process.
I hear you talking about something and I don't think we're always even answering the same question because there are many complicated things that people who receive our services and the providers who are delivering services are trying to operate within our complicated system. And so I do think um there are there are opportunities for us to improve, but I think as far as communication, one thing that's important for all of us is to um like what I've been doing is really listening to what people are talking about and take the complicated part of our system and tease it apart and um resolve the the barriers because sometimes I think we shortcut um what we're thinking we're trying to resolve and we all of our jobs is really to think about the con the system and the complexities of it that people are trying to navigate.
For our waiver case managers. One of mine this year had eight individuals in and out of the hospital this this summer. I don't we don't stop providing care at that time but that's not waiver billable time. So to just to expand on Luella's point like we could run that data we can look at the the department could pull the waiver billing time but there's so many other things that we do that are not re reimburseable to the counties.
Our rates for waiver case management have not been changed in quite some time. They are flat rates, 15minute units. Um and they are not sustainable. We've had growing numbers of programs. We have now counties are just trying to manage um overwhelming case loads. Um so it really shouldn't be a surprise that we're struggling as a system um to sustain these services at the level and the quality that we want to.
Ordinances & Resolutions (11)
State manual calling for authorization requests to be processed within 7 days.
Required by US CMS for combating fraud, leading to revalidation efforts.
Program under which Arland Christensen's son receives services via the DD waiver.
Waiver program discussed for assessment variables related to medical needs.
Waiver program Addison Carpenter depends on for services.
Recognizes individual staffing, direct nurse hours, and staff ratios.
DHS's statewide provider revalidation effort mandated by CMS.
Principle guiding community-based services to prevent unnecessary institutionalization.
Legislation creating new requirements for state, lead agencies, and providers regarding service interruptions.
A group being implemented to examine quality, workforce, accountability, and stability of the HCBS case management system.
Legislatively mandated study to determine sustainable rates for waiver case management, due end of 2028.