The Iowa Department of Health and Human Services (HHS), pursuant to the requirements outlined in 42 C.F.R. §430.20, hereby gives notice of the following proposed action regarding Four Walls Exceptions under the State Plan under Title XIX of the Social Security Act Medical Assistance Program (Medicaid).

Summary of Submission:

November 2024, Centers for Medicare & Medicaid Services (CMS) released a final rule which finalized the proposed exception to the Medicaid clinic services benefit four walls requirement, to authorize Medicaid payment for clinic services provided outside the four walls of the clinic for IHS/Tribal clinics. The final rule’s stated intention is that it will “maintain and improve access for the populations served by IHS/Tribal clinics, behavioral health clinics, and clinics located in rural areas. 

Fiscal Impact:

There is no fiscal impact in Medicaid fee-for-service (FFS) expenditures for State Fiscal Year (SFY) 2026 or SFY 2027 related to this amendment.

Public Review and Comments

A copy of the Medicaid State Plan Amendment and this public notice are posted on the HHS website at the following link: https://hhs.iowa.gov/public-notice/2026-07-20/public-notice-state-plan-amendment-spa-ia-25-0016-four-walls-clinic-services.  To reach all stakeholders, non-electronic copies will be made available for review at each local HHS office. 

Submission of Comments

Written comments concerning this notice may be addressed to Quality Improvement and Medical Policy Team, Iowa Department of Health and Human Services, Division of Medicaid, 321 East 12th Street, Des Moines, IA 50319 or may be emailed to [email protected]. Please indicate Four Walls Exceptions in the subject line of the email. 

All written and emailed comments must be received within 30 days from the issuance of this notice and no later than August 19, 2026 by 4:30 p.m.

Submitted by:

Lee Grossman, Medicaid Director

Iowa Department of Health and Human Services