AASD and DSD eList announcement

Date: June 23, 2026
To: Lead agency staff and other interested parties
From: DHS Aging and Adult Services and Disability Services divisions
Purpose: To announce changes to support plan signature compliance requirements
Effective: Aug. 1, 2026
Contact: For questions related to Alternative Care (AC), Essential Community Supports (ECS) and Elderly Waiver (EW), contact dhs.aasd.hcbs@state.mn.us. For questions related to disability waivers, use the DSD Contact Form.

Support plan signature compliance changes

DHS updated the support plan signature policy and resources to align with federal requirements.

Legal authority

DHS is making this change due to the federal Centers for Medicare & Medicaid Services (CMS) requirement, CFR §441.301 (c)(2)(ix)(x). This requirement strengthens safety, continuity of services and program integrity, while ensuring support planning truly reflects a whole-person, team-based approach.

Updated policy

Within 60 calendar days of the assessment or from the initial assessment review (IAR), the case manager/care coordinator must provide the full support plan to and get the signatures from:

· Person.

· Person’s legal representative (if applicable).

· Case manager/care coordinator.

· All providers responsible for delivering services under the plan.

Managed care organizations (MCOs) have 60 calendar days to obtain signatures, aligning with the timeline for counties and Tribal Nations.

All enrolled providers must keep a current copy of the support plan and signatures for their records.

Provider signature requirements

All enrolled providers of waiver/AC/ECS-funded services must sign the support plan. If using the lead agency approval option, the lead agency must sign the support plan.

Non-compliance

DHS will consider support plans non-compliant if the full support plan is not:

· Provided to all required parties within 60 calendar days of the assessment or from the IAR.

· Signed by all required parties.
Note: DHS will not consider support plans to be compliant unless lead agencies obtain signatures within the required timeline. Two attempts to obtain signatures from providers does not meet this requirement.

The DHS Lead Agency Review Team will begin auditing support plans Aug. 1, 2026, using the updated policy. Between Aug. 1, 2026, and July 31, 2027, DHS will not issue corrective actions to lead agencies. Effective Aug. 1, 2027, DHS will begin issuing corrective actions to lead agencies for non-compliance.

DHS actions

DHS updated the following resources:

· CBSM – Support planning for long-term services and supports (LTSS): Comprehensively reviewed, clarified content throughout the page and updated the support plan signature and timeline section to reflect changes outlined above.

· CBSM – Individual community living supports (ICLS): Comprehensively reviewed, clarified content throughout the page and removed language stating ICLS Planning Form, DHS-3751 can be used to meet provider signature requirements.

· ICLS Planning Form, DHS-3751: Clarified content throughout the form and removed the provider signature line because the provider must now sign full support plan.

· CBSM – Provider signature requirements for HCBS support plans: Deleted the page and moved content to CBSM – Support planning for LTSS because DHS no longer allows two attempts to obtain provider signatures or sending partial plans.

· CBSM – FAQs about provider-signature requirements for HCBS support plans: Deleted the page and moved content to CBSM – Support planning for LTSS.

DHS will:

· Send another eList when training is available in TrainLink (early July 2026).

· Update the support plan in the MnCHOICES application (planned for Aug. 20, 2026).

Lead agency actions

Lead agencies must:

· Review the updated resources listed above.

· Share the resources with others in their organization.

· When available, complete the Updated Signature Requirement Policy for Support Plans training in TrainLink by Oct. 31, 2026.
Note: Lead agencies are responsible to track completion of required trainings.

Previous eList announcements

AASD LEAD AGENCY ARCHIVE | DSD LEAD AGENCY ARCHIVE | DSD STAKEHOLDER ARCHIVE