Temporary 245D licensing moratorium exceptions
(Rev. 12/23/2025)
Under the temporary 245D licensing moratorium for Home and Community-Based Services that begins on January 1, 2026, the Minnesota Department of Human Services (DHS) will not accept any new 245D license applications or requests to add additional services to any existing 245D licenses. This pause on issuing new licenses will have an anticipated duration of 24 months, ending December 31, 2027.
To ensure people across Minnesota can access the licensed Home and Community-Based Services they need, a moratorium exception process will be available starting January 1, 2026. The exception process will be based on requests submitted to DHS by the lead agency (county or managed care organization) or Tribal Nation responsible for a person’s waiver case management. This process will allow lead agencies and Tribal Nations with limited provider options to identify a local licensed service need—based on an individual waiver participant’s needs or broader local/regional capacity gaps—and propose a provider to DHS who may then apply for a new 245D license or add the service to an existing license.
There are two scenarios in which an exception request will be accepted by DHS:
- When a lead agency or Tribal Nation identifies a person-specific service need cannot be met within the existing licensed capacity in the county, reservation, or region (e.g., surrounding counties) in which the person wishes to receive services.
- When one or more lead agencies and/or Tribal Nations collectively identify a regional need for new licensed capacity based on the service needs of multiple individuals.
As part of an exception request, lead agencies and Tribal Nations will be required to identify a potential service provider to meet the individual or regional service need.
- If the potential service provider does not already hold a 245D license, the provider will be contacted by DHS to submit a 245D license application which will follow the standard review process and must meet all licensing requirements.
- If the potential service provider does already have a 245D license, the provider will be contacted by DHS to submit information to add the needed service to their existing license.
Being granted a moratorium exception request DOES NOT guarantee that a 245D license will be issued or the addition of a new service to an existing 245D license will be approved. The potential provider must still meet all existing license qualifications and requirements to be issued a 245D license or to add the requested service to their existing 245D license.
DHS asks counties, MCOs, and Tribal Nations to identify personnel who will serve as their agencies’ 245D licensing moratorium liaisons. Lead agency and Tribal Nation moratorium liaisons will be responsible to submit exception requests to DHS. Exception requests submitted to DHS by anyone other than a 245D licensing moratorium liaison will not be accepted.
For more information, see answers to frequently asked questions.
If you have other questions regarding this moratorium, please contact the DHS Licensing Division at licensemoratorium.dhs@state.mn.us.