DSD eList announcement
Date: March 10, 2026
To: Lead agencies and other interested parties
From: DHS Disability Services Division
Purpose: To share overall trends identified during the initial rounds of pre-payment review for certain Medicaid benefits and services available through the Brain Injury (BI), Community Alternative Care (CAC), Community Access for Disability Inclusion (CADI) and Developmental Disabilities (DD) waivers
Contact: DSD Contact Form
Program integrity pre-payment review trends
DHS identified trends when we completed the initial rounds of pre-payment reviews.
We implemented pre-payment reviews as a result of Governor Tim Walz’s executive order (refer to State of Minnesota Executive Order 25-10 [PDF]). The new process allows DHS to review claims for certain Medicaid benefits and services before we pay them as part of a coordinated effort to reduce fraud, waste and abuse in Minnesota’s Medicaid program. For more information, refer to:
This eList announcement includes:
Claims review process overview
DHS contracted with Optum, a third-party vendor, to assist with the new pre-payment review process. Optum:
Claims review for warrant cycle ending Dec. 25, 2025
During the week of Jan. 5, 2026, DHS reviewed flagged claims for the high-risk services from the warrant cycle from Dec. 12 to Dec. 25, 2025. Individualized home supports (IHS) with training was the only DSD service that had claims identified for review during this warrant cycle. Future warrant cycles may include other DSD services.
IHS policy reminder
DHS encourages lead agencies and providers to review the following IHS policies.
IHS has three service options:
IHS with training is only available to adults. Minors (i.e., people age 17 or younger) cannot receive authorization for IHS with training.
If minors need training, lead agencies must use IHS with family training, which provides support and training to the person and/or their family.
For more information, refer to CBSM – IHS.
MMIS instructions about forcing exception codes (i.e., edits)
DHS encourages lead agencies to review the following instructions about Medicaid Management Information System (MMIS) exception codes (ECs) and how to enter IHS with training into MMIS.
Lead agencies cannot rely on MMIS to correctly capture all policy nuance. MMIS has many system limitations and may allow actions that are not allowed in waiver authority. For example, an MMIS EC might be forcible because multiple services use the same EC.
During service agreement entry, MMIS may post ECs with invalid, incorrect or incomplete data or data that conflicts with policy or other MMIS information.
The lead agency worker entering the information into MMIS is responsible for reviewing and resolving all ECs before they approve the service(s) and/or service agreement. Lead agencies must read the instructions in the EC text before they attempt to force it.
Instructions for IHS with training EC
When a lead agency enters IHS with training for a minor, MMIS posts EC 424 because only adults can receive IHS with training. The lead agency cannot resolve the issue by forcing the EC.
Service delivery requirement reminders
The Governor’s executive order and pre-payment review do not replace any current waiver service delivery requirements. Pre-payment review is an additional process. As a reminder, lead agencies and providers must continue to follow all other policies and processes, including the following:
The following sections provide DHS’ general guidance on these service delivery requirement reminders.
Pay staff on time
Employers must pay employees for their time worked. Workers who do not receive compensation for time worked may file wage claims against employers through the Minnesota Department of Labor and Industry.
Align service delivery with approved support plans
During the pre-payment review process, providers must continue to deliver services in compliance with the person’s support plan per 245D requirements and federal disability waiver plan (BI, CAC, CADI and DD) requirements.
245D license holders must:
The pre-payment review process:
Refrain from substituting alternative services to avoid pre-payment review
Providers cannot request specific services or ask to substitute services to bypass the pre-payment review process. Waiver services are not interchangeable. Service eligibility and covered services are waiver service specific.
Lead agency staff are responsible for developing a person-centered support plan with the person that meets their assessed needs.
Example
Respite cannot replace IHS. A person is eligible to receive respite if their primary caregiver(s) are absent or need relief from caregiver duties, as explained on CBSM – Respite. IHS provides support in community living service categories for people who live in their own home (including with family), as explained on CBSM – IHS. A single person may be eligible for one or both services, but IHS and respite are not interchangeable.
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