There are two high-profile and time-sensitive efforts underway right now, and we are fielding questions from many members about these efforts. In the interest of providing some clarity, I wanted to summarize what we know right now.
Revalidate 2026
Starting with the off-cycle revalidation project, the information we are hearing seems to change day-to-day. As a reminder, this began late last year as part of the state’s program integrity efforts, and to satisfy a corrective action plan that CMS imposed on DHS. The plan included unannounced site visits to each licensed facility operated by all providers that deliver the high-risk services that were identified by the Governor. DHS pulled in employees from other state agencies and multiple divisions within DHS to complete the effort by the very aggressive deadline of May 31, 2026.
As we understand it, all providers that were not able to complete revalidation by May 31 were issued disenrollment (i.e. termination) letters. The reason for not completing revalidation does not matter, and it may not be the provider’s fault, but the state had to complete the project by May 31. DHS will send these disenrollment letters either through the US Postal Service, or to registered MN-ITS mailbox accounts in the PRVLTR folder. When a provider is in a terminated status, they can continue to provide services, but they are not able to bill for any services, and they are not able to be issued any new service authorizations or rate exceptions. To restore valid provider status, an appeal must be filed.
Revalidation-related terminations can occur when the revalidation application is not submitted after 2 notifications from DHS, when requested documents were not submitted within the required timeframe, or if criteria required during an on-site visit were not met. Providers have 60 days from the date of notification of termination to file an appeal following the instructions on the termination letter. The sooner an appeal is filed, the sooner the provider’s enrollment can be restored, and DHS is recommending providers file appeals related to revalidation within 7 days.
Now, with all that said, we are getting reports that the process does not always go as intended. There seem to be many complicating factors, such as open regular-cycle revalidations that were in-process then this effort started, inaccuracies or inconsistencies in the provider’s record in the Minnesota Provider Screening and Enrollment (MPSE) portal, multiple open tickets for the same issue at the Provider Resource Center, unprocessed changes in ownership, and temporary and/or overworked staff at DHS making errors. As the deadline got closer, it was harder to get through to DHS in all channels.
In a meeting on Friday, May 29, DHS reported that the disenrollment/termination letters should contain the details about what is still needed. They advise providers to read the letters in full and follow the instructions carefully in filing an appeal. Appeals will be processed in the order they are received. When submitting documents, providers should make sure they are full, complete, and accurate. If background studies are involved as part of the reason for disenrollment, it is more complicated, and DHS will be adding to the FAQ page with more information. It sounds like many of the disenrollments should be relatively easy to resolve, and may be completed by the next billing cycle.
DWRS Rate Remediation
Now, turning to rate remediation, there are still misunderstandings of this complex process, and not only among providers, but among lead agency staff as well. Here are some helpful points to keep in mind when evaluating what rate should be assigned to an individual.
- Rate remediation only applies to framework rates, not rate exceptions.
- Only service authorizations with effective dates between January 1, 2026 and March 31, 2026 require rate remediation. All authorizations with effective dates of April 1, 2026 or after will have been approved at the correct 2026 rate.
- The rates currently assigned to authorizations with effective dates between January 1, 2026 and March 31, 2026 will be terminated by DHS and lead agencies as of May 31, 2026 and new rates will become effective from June 1, 2026 to the end of the span. These new rates will be based on the amended 2026 rate frameworks.
- DHS has sent spreadsheets to lead agencies that contain each individual rate that needs to be remediated, and lead agencies will be sending spreadsheets to providers with rate remediation information on the individuals they support.
- Providers will be asked to sign off on the forced terminations of the current rates as of May 31, 2026, and the new rates effective June 1, 2026 through the end of the individual’s span. Providers are encouraged to check the new rate for accuracy using the amended 2026 frameworks.
- Providers will choose whether to do nothing and accept the rates they were paid for each individual through May 31, 2026, or to indicate that they want to go through claim voids and rebilling from the effective date of each authorization through May 31, 2026 at the amended 2026 rates.
Be aware that counties are proceeding at different speeds and with different timelines, so you may have different sets of instructions from different counties. I have received reports that some counties are not following the steps correctly, and may not have calculated amended rates correctly, so it would be a good idea to double-check their work.
Not only are the amended and approved 2026 rate frameworks available on the DHS website, we have unlocked versions of both available on ours. Either version can be used to calculate a person’s rate. I have noticed some of the frameworks on the DHS website have the deaf/hard of hearing add-on turned on by default, and some have a county pre-selected in the Regional Variance Factor. Check all inputs to make sure they are accurate for the individual whose rate you are calculating.
Feel free to use ARRM or me as a resource if you have questions, and we will do our best to help you. We will get through these complicated efforts!
-Ken Bence, Director of Research, Analysis and Policy