SF4222 (Legislative Session 94 (2025-2026))

Medical assistance provider enrollment requirements modifications

Related bill: HF3423

AI Generated Summary

Purpose

This bill aims to strengthen and tighten how medical assistance (Medicaid) providers enroll, revalidate, and remain enrolled in Minnesota’s system. It expands who must be screened (controlling individuals), adds new oversight requirements for providers, and increases penalties and safeguards to prevent fraud, waste, and abuse. It also creates more formal processes for monitoring provider performance and ensuring compliance with state and federal rules.

Main provisions and what the bill seeks to accomplish

  • Define “controlling individual” and “managerial official”
    • Identifies who must be screened and held accountable for a provider’s actions, including owners, officers, designated agents, compliance officers, and certain board leaders.
    • Sets who is not considered a controlling individual (with some exceptions) to avoid unnecessary scope (e.g., some financial institutions and certain government officials).
  • Strengthen provider management oversight
    • License holders must designate a managerial staff person to oversee program management and compliance.
    • The designated manager must ensure compliance with licensing rules, oversee incident and emergency reporting, protect clients’ rights, ensure staff competency and training, and drive ongoing program improvements.
    • The designated manager must have at least three years of supervisory experience in a program serving vulnerable adults or children.
  • Expand and standardize background checks and revalidation
    • Requires comprehensive background studies (including fingerprinting) for individuals with ownership, control interest, or management roles.
    • Revalidation (reauthentication of a provider’s enrollment) occurs on a set schedule and includes pre-enrollment and post-enrollment checks.
    • General revalidation every five years; certain provider types (e.g., CFSS, EIDBI) and those deemed high-risk every three years.
    • Revalidation includes a 30-day notice, a 30-day response window, and a 15- or 60-day action timeline if deficiencies aren’t fixed, with suspension of billing authority if not remedied (no related administrative appeal).
    • High-risk designations may allow the state to withhold payment during revalidation.
  • Require ongoing verification and site visits
    • Before enrolling and throughout enrollment, the state must verify licenses, run database checks, and conduct background studies.
    • Providers must allow unannounced site visits; visits occur before first payment, within 12 months of starting to bill, and before revalidation.
  • Financial safeguards and bonding
    • Certain medical equipment and supply providers (DMEPOS) must obtain surety bonds, with amounts tied to revenue and enrollment status.
    • Other providers may be required to obtain surety bonds or cash reserves as a condition of enrollment or continued enrollment (with DHS as the bond obligee).
    • Bond amounts vary (e.g., initial enrollment, revalidation; specific thresholds like 50,000 or 100,000 or 10% of payments, depending on provider type and revenue).
    • There are exceptions (e.g., certain centers, Indian Health Service, pharmacies, rural health clinics) where bonds are not required.
    • Cash reserves of at least $100,000 or 10% of Medicaid payments in the prior 12 months may be required.
  • Compliance programs
    • DHS may require providers in certain sectors to implement a CMS-like compliance program with core elements (policies, training, response to improper conduct, monitoring, and reporting of overpayments).
    • If a compliance officer is designated, they must carry out duties such as policy development, staff training, responding to issues, and reporting to the state.
  • Provider enrollment and revalidation procedures
    • Providers must enroll every location where direct services are provided.
    • If enrollment materials are incomplete or missing, enrollment can be denied.
    • Correspondence and notifications may be sent electronically.
  • Provider suspensions and terminations
    • The commissioner can suspend a provider’s ability to bill if requirements aren’t met, with no administrative appeal for the suspension.
    • The commissioner can revoke enrollment for lack of documentation or repeated documentation failures, and may terminate enrollment based on ownership, prior Medicare/Medicaid actions, or related disqualifications.
    • A pattern of documentation failures is defined as failing to maintain or provide access to required records on more than one occasion.
  • Revalidation and ongoing oversight requirements (summary)
    • Regular revalidation of enrollment with unannounced site visits tied to the due date.
    • Ongoing verification, background checks, and potential suspension or termination for noncompliance or fraud indicators.
    • Publication of provider risk designations and designations of limited/moderate/high risk, with corresponding enforcement tools.

Significant changes to existing law

  • Introduces or expands the concept of “controlling individual” and “managerial official” to determine who must undergo background checks and enrollment screening.
  • Mandates designated managers with formal oversight duties and minimum supervisory experience.
  • Broadens and standardizes background studies, fingerprinting, and pre-/post-enrollment checks for providers and key individuals.
  • Establishes a risk-based framework (limited, moderate, high risk) for provider enrollment, with different requirements and potential payment-withholding for high-risk providers.
  • Expands the use of unannounced site visits as a standard condition of enrollment and revalidation.
  • Requires cash reserves and surety bonds for many providers, with specified minimum amounts and exceptions.
  • Requires the development and implementation of comprehensive compliance programs for certain providers.
  • Tightens the process and timelines for enrollment, revalidation, suspensions, and terminations, reducing opportunities to circumvent oversight.
  • Mandates regular reporting and data collection (annual DHS report) on provider operations and visits.

Impact and who is affected

  • Providers enrolling in or currently enrolled in Minnesota’s Medicaid program will face new screening, oversight, and financial requirements.
  • Organizations with ownership or leadership roles in service providers (including nonprofit boards and executives) will be subject to enhanced background checks and compliance obligations.
  • High-risk provider types will face more frequent revalidation, tighter oversight, and potential payment holds.
  • The Department of Human Services and CMS-related processes will receive expanded duties for monitoring, reporting, and enforcement.

Relevant Terms - controlling individual - managerial official - compliance officer - preenrollment and postenrollment checks - background study - fingerprinting - revalidation - unannounced site visit - limited risk / moderate risk / high risk (provider risk levels) - surety bond - cash reserves - CMS core elements - Department of Human Services (DHS) - Minnesota Health Care Program Provider Manual - Centers for Medicare and Medicaid Services (CMS) - medical assistance (Medicaid) - provider enrollment - withhold payment - high-risk designation - compliance program - documentation pattern - enrollment suspension - enrollment termination

(End of summary)

Bill text versions

Past committee meetings

Actions

DateChamberWhereTypeNameCommittee Name
March 09, 2026SenateActionIntroduction and first reading
March 09, 2026SenateActionReferred toHealth and Human Services
March 23, 2026SenateActionAuthor added

Citations

 
[
  {
    "analysis": {
      "added": [],
      "removed": [],
      "summary": "Cites Minnesota Statutes 2024, section 142B.01, subdivision 8.",
      "modified": []
    },
    "citation": "142B.01",
    "subdivision": "Subd.8"
  },
  {
    "analysis": {
      "added": [],
      "removed": [],
      "summary": "Cites Minnesota Statutes 2024, section 245A.02, subdivision 5a.",
      "modified": []
    },
    "citation": "245A.02",
    "subdivision": "Subd.5a"
  },
  {
    "analysis": {
      "added": [],
      "removed": [],
      "summary": "Cites Minnesota Statutes 2024, section 245D.081, subdivision 3.",
      "modified": []
    },
    "citation": "245D.081",
    "subdivision": "Subd.3"
  },
  {
    "analysis": {
      "added": [],
      "removed": [],
      "summary": "Cites Minnesota Statutes 2024, section 256B.04, subdivision 5.",
      "modified": []
    },
    "citation": "256B.04",
    "subdivision": "Subd.5"
  },
  {
    "analysis": {
      "added": [],
      "removed": [],
      "summary": "Cites Minnesota Statutes 2024, section 256B.0949, subdivision 17.",
      "modified": []
    },
    "citation": "256B.0949",
    "subdivision": "Subd.17"
  },
  {
    "analysis": {
      "added": [],
      "removed": [],
      "summary": "Cites Minnesota Statutes 2025 Supplement, section 256B.04, subdivision 21.",
      "modified": []
    },
    "citation": "256B.04",
    "subdivision": "Subd.21"
  },
  {
    "analysis": {
      "added": [],
      "removed": [],
      "summary": "Cites Minnesota Statutes 2025 Supplement, section 256B.0759, subdivision 4.",
      "modified": []
    },
    "citation": "256B.0759",
    "subdivision": "Subd.4"
  },
  {
    "analysis": {
      "added": [],
      "removed": [],
      "summary": "Cites Minnesota Statutes 2025 Supplement, section 256B.0949, subdivision 16.",
      "modified": []
    },
    "citation": "256B.0949",
    "subdivision": "Subd.16"
  },
  {
    "analysis": {
      "added": [],
      "removed": [],
      "summary": "Cites Code of Federal Regulations Title 42, Subpart E (provider enrollment background checks).",
      "modified": []
    },
    "citation": "42 CFR 455 Subpart E",
    "subdivision": "Subpart E"
  },
  {
    "analysis": {
      "added": [],
      "removed": [],
      "summary": "Cites CFR Title 42, Section 455.412 (license verifications).",
      "modified": []
    },
    "citation": "42 CFR 455.412",
    "subdivision": ""
  },
  {
    "analysis": {
      "added": [],
      "removed": [],
      "summary": "Cites CFR Title 42, Section 455.436 (pre- and postenrollment checks).",
      "modified": []
    },
    "citation": "42 CFR 455.436",
    "subdivision": ""
  },
  {
    "analysis": {
      "added": [],
      "removed": [],
      "summary": "Cites CFR Title 42, Section 424.518 (designations of provider risk levels).",
      "modified": []
    },
    "citation": "42 CFR 424.518",
    "subdivision": ""
  },
  {
    "analysis": {
      "added": [],
      "removed": [],
      "summary": "Cites CFR Title 42, Section 455.450 (surety bonds for enrollment).",
      "modified": []
    },
    "citation": "42 CFR 455.450",
    "subdivision": ""
  },
  {
    "analysis": {
      "added": [],
      "removed": [],
      "summary": "Cites Minnesota Statutes 80A.45 (ownership-related exemptions for certain entities).",
      "modified": []
    },
    "citation": "80A.45",
    "subdivision": ""
  },
  {
    "analysis": {
      "added": [],
      "removed": [],
      "summary": "Cites Minnesota Statutes 80A.46 (exemption provisions related to ownership).",
      "modified": []
    },
    "citation": "80A.46",
    "subdivision": ""
  },
  {
    "analysis": {
      "added": [],
      "removed": [],
      "summary": "Cites Minnesota Statutes 290.05 (tax-related provisions referenced in this context).",
      "modified": []
    },
    "citation": "290.05",
    "subdivision": ""
  },
  {
    "analysis": {
      "added": [],
      "removed": [],
      "summary": "Cites Minnesota Statutes 144A.484 (home care licensing references).",
      "modified": []
    },
    "citation": "144A.484",
    "subdivision": ""
  },
  {
    "analysis": {
      "added": [],
      "removed": [],
      "summary": "Cites Minnesota Statutes Chapter 144G (assisted living facilities).",
      "modified": []
    },
    "citation": "144G",
    "subdivision": ""
  },
  {
    "analysis": {
      "added": [],
      "removed": [],
      "summary": "Cites Minnesota Statutes 245C.08, Subd.1 (background studies with databases and fingerprinting considerations).",
      "modified": []
    },
    "citation": "245C.08",
    "subdivision": "Subd.1"
  },
  {
    "analysis": {
      "added": [],
      "removed": [],
      "summary": "Cites Minnesota Statutes 256B.051 (surety bonds related to enrollment).",
      "modified": []
    },
    "citation": "256B.051",
    "subdivision": ""
  },
  {
    "analysis": {
      "added": [],
      "removed": [],
      "summary": "Cites Minnesota Statutes 256B.0659 (additional bond requirements referenced in this bill).",
      "modified": []
    },
    "citation": "256B.0659",
    "subdivision": ""
  },
  {
    "analysis": {
      "added": [],
      "removed": [],
      "summary": "Cites Minnesota Statutes 256B.0701 (additional enrollment/sanction provisions).",
      "modified": []
    },
    "citation": "256B.0701",
    "subdivision": ""
  },
  {
    "analysis": {
      "added": [],
      "removed": [],
      "summary": "Cites Minnesota Statutes 256B.85 (enrollment controls and related provisions).",
      "modified": []
    },
    "citation": "256B.85",
    "subdivision": ""
  },
  {
    "analysis": {
      "added": [],
      "removed": [],
      "summary": "References Minnesota Statutes 14.386 (administrative procedure provisions not applying in this context).",
      "modified": []
    },
    "citation": "Minnesota Statutes 14.386",
    "subdivision": ""
  },
  {
    "analysis": {
      "added": [],
      "removed": [],
      "summary": "Cites Minnesota Statutes 256B.064 (sanctions and related enforcement provisions).",
      "modified": []
    },
    "citation": "256B.064",
    "subdivision": ""
  },
  {
    "analysis": {
      "added": [],
      "removed": [],
      "summary": "Cites Minnesota Statutes 245A.04 Subd.1 (provider duties and requirements).",
      "modified": []
    },
    "citation": "245A.04",
    "subdivision": "Subd.1"
  },
  {
    "analysis": {
      "added": [],
      "removed": [],
      "summary": "Cites Minnesota Statutes 245A.65 Subd.1 (background checks and related screening).",
      "modified": []
    },
    "citation": "245A.65",
    "subdivision": "Subd.1"
  },
  {
    "analysis": {
      "added": [],
      "removed": [],
      "summary": "Cites Minnesota Statutes 245D.11 Subd.2 (incident reports and related procedures).",
      "modified": []
    },
    "citation": "245D.11",
    "subdivision": "Subd.2"
  },
  {
    "analysis": {
      "added": [],
      "removed": [],
      "summary": "Cites Minnesota Statutes 245D.04 (rights and protections of persons served).",
      "modified": []
    },
    "citation": "245D.04",
    "subdivision": ""
  },
  {
    "analysis": {
      "added": [],
      "removed": [],
      "summary": "Cites Minnesota Statutes 245D.07 (program evaluation/quality improvements).",
      "modified": []
    },
    "citation": "245D.07",
    "subdivision": ""
  },
  {
    "analysis": {
      "added": [],
      "removed": [],
      "summary": "Cites Minnesota Statutes 245D.071 (outcomes and progress measures).",
      "modified": []
    },
    "citation": "245D.071",
    "subdivision": ""
  }
]

Progress through the legislative process

17%
In Committee
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