Yesterday afternoon (January 8, 2026), the Minnesota Department of Human Services (“DHS”) alerted providers that the Centers for Medicare & Medicaid Services (“CMS”) directed Minnesota to freeze new provider enrollments in over a dozen categories of health care services, including:
- Adult Companion Services
- Adult Day Services
- Adult Rehabilitative Mental Health Services
- Assertive Community Treatment
- Community First Services and Supports
- Early Intensive Developmental and Behavioral Intervention
- Housing Stabilization Services
- Individualized Home Supports
- Integrated Community Supports
- Intensive Residential Treatment Centers
- Night Supervision Services
- Nonemergency Medical Transportation Services
- Recovery Peer Support
- Recuperative Care
DHS stated that this freeze is the latest action in response to concerns over fraud, particularly in government-run health care programs. This directive by CMS, however, indicates that the federal government is stepping in to assert more control over Medicaid programs typically overseen by state agencies. Notably, DHS had already announced a two-year licensing freeze on home and community-based services and adult day programs.
According to DHS, a start date for the freeze is yet to be determined, and as of right now, there is no clear plan for implementing the necessary operational processes and updates needed to achieve this broad enrollment freeze, or determine how pending enrollment applications already in queue will be handled. Once implemented, however, the freeze is set to last at least six months.
Currently enrolled providers can continue to operate as usual and the freeze on new provider enrollments will not affect new member enrollment in existing programs. DHS also advises that it will issue exceptions to add new providers where capacity is needed, although any exception will require written approval from CMS. It is unclear at this juncture how such need will be determined or what the process or criteria will be to enroll new providers under an exception. The freeze on new enrollments coupled with the widespread payment withholds and prepayment reviews which have delayed or stopped payment to providers raises questions about how DHS will ensure that Medicaid recipients in need will continue to have access to necessary services.
If you are an affected provider and have questions about this pending licensing moratorium, or are facing adverse DHS or CMS action, reach out to the health care regulatory attorneys at Winthrop & Weinstine, P.A.