In 2014, The Centers for Medicare and Medicaid (CMS) made rules defining HCBS and outlining under what circumstances HCBS funding can be used. The goal of these rules was to make sure HCBS funding is truly used to support people to lead non-institutional lifestyles. The rules required HCBS to be provided in such a way that recipients:
are integrated into their communities;
are supported to make every day and major life choices;
access community life and resources;
experience autonomy; and
are afforded other important consumer protections and human rights.
Reporting New Settings
Effective March 17, 2023, HCBS Waiver and Habilitation providers must report and receive approval for new residential and non-residential settings prior to using HCBS funding in the setting. March 17, 2023, marked the end of the transition period for states to fully comply with the Centers for Medicare & Medicaid Services (CMS) final rule for HCBS settings. The HCBS settings rule requires states to ensure all settings where HCBS waiver and Habilitation services are provided comply with HCBS settings requirements rule prior to receiving HCBS funding in the setting.
Providers wishing to discontinue or disenroll from specific services, settings or the entire organization may contact their HCBS Specialist for assistance.
Iowa Medicaid has had a robust HCBS quality oversight system in place for over thirty years. This quality oversight system includes regular, ongoing review of providers of HCBS waiver and Habilitation services.
Iowa Medicaid's QIO HCBS team is responsible for all quality oversight activities for the HCBS waiver and Habilitation providers, including the review and assessment of HCBS settings
List items for HCBS Quality Oversight
Quality oversight includes, but is not limited to, annual provider self-assessment, Periodic or Certification Reviews, CNRS Periodic Reviews, Focused Reviews and review of incidents and complaints (also known as Targeted Reviews).
As part of our ongoing commitment to ensuring high-quality care, Iowa Medicaid's Quality Improvement Organization (QIO) Home and Community Based Services (HCBS) unit conducts quality oversight reviews of HCBS providers. These reviews help us verify the accuracy of responses on your most recent provider quality self-assessment and to ensure your compliance with current laws, rules, requirements, and best practices. Quality oversight includes, but is not limited to, annual provider self-assessment, Periodic or Certification Reviews, CNRS Reviews, Focused Reviews and review of incidents and complaints (also known as Targeted Reviews).
Periodic Reviews: All non-certified providers receive a Periodic Review at least once in a five-year cycle. During the review process, responses on the latest SA are verified to evidence found in member and personnel records and compared to other evidence such as Residential Assessments for selected members.
Certification Reviews: Certification Reviews occur 270 days after the initial enrollment of an HCBS-certified provider. Subsequent certification reviews determine the level of certification for the provider. Providers can be recertified for up to a maximum of three years. The Certification Review process is the same as the Periodic Review process but results in a score that determines the provider’s certification level.
Focused Reviews: Providers are semi-randomly selected each year to participate in a Focused Review, and all providers receive a Focused Review once in a five-year cycle. The Focused Review subject is determined annually and based on historical data and Iowa Medicaid need.
Targeted Reviews: Providers may be subject to a Targeted Review based on a complaint towards a specific provider or a serious incident or pattern of incidents. Complaints and incidents may be related to HCBS setting rule non-compliance. A Targeted Review may be completed as a desk review or an onsite review.
Corrective Action Plan Guidelines
When you receive a quality oversight review, you will get a report detailing findings related to the review. Comments will include descriptions of findings including but not limited to, any commendations for areas which the review team found to be exemplary, recommendations for suggested organization actions and areas where corrective action is required to come into compliance with current laws, rules, requirements, and best practices as well as organization policy and responses on the most recent provider quality self-assessment. When changes are required, the report will give parameters in which to develop corrective actions. You have thirty (30) calendar days from the date of this report to develop and submit a CAP.
Components of an Effective CAP
A comprehensive and acceptable CAP must contain the four essential components list below. Each component must be clearly defined, measurable, and time-bound to ensure effective implementation and sustained compliance.
Understanding of the Problem
Clearly acknowledge the identified problem(s).
Explain why it might have happened (root cause analysis).
Steps for Fixing the Problem
List specific steps to solve the problem.
Set clear deadlines for each step that align with the corrective action process.
Spell out necessary changes to written policies, practices, or both.
If updating or creating a policy, submit the draft policy with the CAP.
Name who's responsible for each task.
Training Your Team
Explain how you will train or retrain affected staff on the changes.
It may be necessary to include information about the content of training when submitting the CAP.
Set a training schedule that aligns with the corrective action process.
Check that staff understand the changes.
Plan for future training if needed.
Monitoring and Sustainability Plan
Develop a plan for monitoring if the changes you make work to solve the problems (internal monitoring).
Decide how you will know your plan is working and what kind of information you will gather.
Set a schedule for monitoring that aligns with the corrective action process.
Explain how you will document monitoring activities.
Explain what you will do if new, similar problems come up.
The QIO HCBS unit is committed to your success. Your HCBS specialist is available for technical assistance and guidance as you develop your CAP. Please note, if you are unable to provide an acceptable CAP after two attempts, the QIO HCBS unit will provide a CAP for your organization to carry out to ensure timely completion of this review.
A separate Provider Quality Self-Assessment for Community-Based Neurobehavioral Rehabilitation Services (CNRS) providers can be found on the CNRS webpage.
The HCBS Provider Quality Self-Assessment is required of all providers enrolled for the services identified, regardless of whether those services are currently being provided. The self-assessment must be completed, submitted and approved at application, annually and anytime there is a change in the provider's enrollment that warrants an updated self-assessment.
In July 2025, the Provider Self-Assessment (PSA) Application was launched to streamline communication with HCBS Quality Oversight specialists and providers. The application is accessed within the Iowa Medicaid Portal Application (IMPA). A training was developed to communicate expectations and explain functionality of the application.
To report an issue or voice a complaint related to an HCBS or CNRS provider, or for general questions about HCBS incident reporting, please email the Incident and Complaint team at hcbsir@hhs.iowa.gov
