Exercise of Enforcement Discretion for Requirements for a Medicaid Fee-For-Service Grievance System for Home and Community-Based Services Until December 2027
The Center for Medicaid and CHIP Services (CMCS) is issuing this CMCS Informational Bulletin (CIB) to announce that, until December 31, 2027, CMS does not anticipate taking enforcement action against states with respect to the FFS grievance system requirements at 42 CFR §§ 441.301(c)(7), 441.464(d)(5), 441.555(e), and 441.745(a)(1)(iii) (“FFS grievance system requirements”) t hat were issued as part of the Ensuring Access to Medicaid Services final rule (Access rule).1 Previously, states were required to develop and implement this system by July 9, 2026.
Issued by: Centers for Medicare & Medicaid Services (CMS)
Issue Date: February 26, 2026
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