Frequently asked questions about provider-signature requirements for HCBS support plans
Page posted: 1/5/17
Page reviewed: 6/14/17
Page updated: 10/22/18
This page includes answers to frequently asked questions about the requirement to have providers sign home and community-based services (HCBS) support plans. For more information, see CBSM – Provider-signature requirements for HCBS support plans.
Why is this a new requirement?
This requirement brings Minnesota into compliance with the Centers for Medicare and Medicaid Services’ (CMS) expectations. The CMS requirement applies to when and how lead agencies inform providers of their role in a person’s plan. The provider’s signature indicates their acknowledgement of the services and supports in the plan and their agreement to deliver them as outlined.
When does this requirement begin? Do I need to update all current plans to meet this new requirement?
The provider-signature requirement was effective Jan. 6, 2017. All plans created or updated on or after Jan. 6, 2017, must meet this requirement. You do not need to update plans completed before Jan. 6, 2017 until they require either changes or renewal.
There are two different signature pages for the 6791-eDoc series. Which signature page do I use?
If you use the 6791-eDocs series for support plans, document provider signatures on the MnCHOICES Coordinated Services and Supports Plan (CSSP) Signature Sheet, DHS-6791D (PDF). DHS will remove the signature section on the MnCHOICES CSP with the CSSP form, DHS-6791B (PDF) and alert you when that update is complete.
When the provider signs the plan, do they agree to only their portion of the plan?
Yes, when the provider signs the plan, they agree only to the portion of the plan that is necessary for the provision of the service(s) they provide.
What if the person does not want to send any part of the support plan to the provider?
The person may decide that some providers should not receive any part of the support plan. For example, depending on the type of service the provider delivers, they may not need the plan’s person-centered information in order to deliver services. If the person makes an informed choice not to send the plan to a provider, the lead agency would not ask the provider to sign the plan.
Will DHS update support plan forms so that I can easily obtain signature electronically?
DHS is researching the possibility of obtaining this information electronically. At this time, you must obtain provider signatures using paper documentation. However, if the lead agency currently has a method to obtain signatures electronically, those signatures would meet this requirement.
Can I use the EW Individual Community Living Supports (ICLS) Planning Form or Residential Services Tool (RS Tool) to obtain provider signatures?
Yes, you can send either the RS Tool or the ICLS Planning Form, DHS-3751 (PDF) to the provider in lieu of the entire support plan if the person makes an informed choice to do so. The ICLS Planning Form includes a provider-signature field. You can send the RS Tool with the applicable signature sheet (e.g., DHS-6791D) to obtain the provider signature.
Does this requirement change CDCS requirements?
No. Under CDCS, providers and financial management services (FMS) providers are not required to sign the signature page (e.g., DHS-6791D). The person is developing the plan and choosing his/her own providers, so he/she is not required to have providers sign.
If the person uses CDCS, he/she, his/her representative (if applicable) and the lead agency representative are required to sign both the signature page on the CDCS Community Support Plan, DHS-6532 (PDF) and the CSSP Signature Sheet, DHS-6791D (PDF).
Does this requirement apply to providers who deliver approval-option: purchased-item services (formerly Tier 3)?
No, providers who deliver purchased-item services do not need to sign the person’s support plan.
For health plans, does this requirement apply only to people on EW? Or does it also apply Community Well members who may only receive PCA?
The provider-signature requirement applies to people on EW only – not Community Well members who are only receiving PCA services.
Does this requirement apply to people who receive PCA services?
If the person is on the waiver and receiving PCA services, the lead agency is required to send the support plan to the PCA provider for a signature.
If the person is receiving PCA services and is not on a waiver, the lead agency is not required to obtain the PCA provider signature on the support plan.
When a person’s support plan changes, do I need to obtain the provider’s signature again?
Yes. When there are changes to the plan that affect how the service is provided (e.g., changes to service frequency, number of units, updated tasks assigned to the provider, addition of new a provider, etc.) you must:
The signatures document both the person’s and the provider’s agreement to the plan’s changes.
If there is a statewide rate change (typically referred to as COLA), do I need to obtain the provider’s signature again?
No, you do not need to obtain the provider’s signature again for plan changes related to rates only. If the change were related to anything else (e.g., service frequency, new service, etc.), you would need to obtain new signatures from both the person and the provider.
Can all providers sign the same signature sheet?
Yes, but this is not required. Each provider may receive and sign their own signature sheet.
If the person makes an informed choice to share his/her entire plan with all of his/her provider(s), all providers may sign the same signature sheet.
Does the person need to sign each provider’s signature sheet?
No, the person does not need to sign each provider’s signature sheet. The person must sign the complete support plan.
Can I document a provider’s verbal agreement to the support plan?
No, you cannot document the provider’s verbal agreement to the plan. CMS requires that there is written documentation of the provider’s acknowledgement and agreement to the support plan.
What if, after two attempts, I am not able to obtain a signature from a provider?
If you do not receive the provider’s signature after two attempts, you have satisfied this requirement. You should record the dates of all signature requests in the person’s record.
Do informal caregivers need to sign the support plan?
No, informal caregivers are not required to sign the plan.
Who is authorized to sign the support plan within provider agencies?
The provider agency determines which staff are authorized to sign support plans. DHS does not have a requirement on who this staff should be.
How have providers been notified that their signatures are now required on the support plan?
DHS sent an eList from AASD and DSD and published information in the MHCP newsletter.
Can providers choose not to receive a person’s support plan?
No. The person chooses who receives a copy of the support plan, and the chosen providers must accept the plan.
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