CMS Extends Timeline to Complete HCBS Transition Work

Centers for Medicare & Medicaid Services (CMS) Informational Bulletin

The Centers for Medicare & Medicaid Services (CMS) has released an informational bulletin noting that states will have an additional three years (until 2022) to comply with the home and community-based settings rule.

The informational bulletin notes that “…states should continue progress in assessing existing operations and identifying milestones for compliance that result in final Statewide Transition Plan approval by March 17, 2019. However, in light of the difficult and complex nature of this task, we will extend the transition period for states to demonstrate compliance with the home and community based settings criteria until March 17, 2022 for settings in which a transition period applies. We anticipate that this additional three years will be helpful to states to ensure compliance activities are collaborative, transparent and timely.”  You may read more at


What this means for Pennsylvania’s Office of Developmental Programs

Compliance with the rule and the requirements of the transition plan have not changed. The CMS bulletin however provides three additional years to fully meet the settings requirements.


  • The service definitions in the proposed ODP Consolidated and P/FDS waivers will remain the same. We will consider extending the dates for compliance with Community Participation Support requirements and limiting facility based services to a maximum of 150 participants at any one time.


  • Waiver transition plans will be revised to initiate provider self-assessments for settings compliance to the spring of 2018 (originally scheduled for the fall of 2017).


  • Waiver transition plans will be revised to build in additional time for providers that are found to be out-of-compliance so they can come into compliance by March 17, 2022.


For more information about the Community HealthChoices Waiver Transitions; You can read our original post here.

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