March 26, 2026
Chair Hoffman and Members of the Committee,
Re: SF 476 – Human Services Policy Omnibus (Continuity of Care Protections)
The Minnesota Council on Disability appreciates the opportunity to provide testimony in support of SF 476, the Human Services Policy omnibus, particularly its focus on continuity of care during fraud investigations.
MCD serves as a liaison between Minnesotans with disabilities and the legislature. In recent months, we have heard consistently from community members who have experienced significant service disruptions because of the state’s response to fraud. While we support strong fraud prevention, many of these actions have been implemented without sufficient safeguards to ensure continuity of care for individuals who rely on these services to live independently.
The result has been uncertainty, instability, and, in some cases, immediate risk to health and housing. These concerns were reflected in our Legislative Priorities Survey and Legislative Forum, where individuals and families shared the real-world consequences of service interruptions.
Given this urgency, we strongly appreciate that Article 1 is dedicated to continuity of care protections. The bill establishes a continuity of care team within the Department of Human Services that is responsible for:
- Identifying individuals at risk of service disruption due to payment withholds
- Providing timely notification to impacted individuals, lead agencies, ombudsman offices, and case managers
- Coordinating contingency plans to maintain services
Importantly, the bill prohibits payment withholds until continuity protections are in place and includes a “good cause” exception when alternative providers are not available.
These provisions represent a meaningful step toward person-centered fraud prevention, and we urge the committee to retain this language as the bill moves forward.
We also support several additional provisions that improve access to services and strengthen protections for people with disabilities, including:
- Increased flexibility for unit-based services such as In-Home Support with Training (monthly vs. daily limits)
- Greater flexibility for shared services within CFSS budget and agency models
- Stronger maltreatment reporting and clarified lead agency responsibilities
- Housing Stabilization Services redesign
- Prohibiting facilities from requiring a guardian or conservator as a condition of admission
- Policies addressing the concentration of group homes
- Increased transparency in corporate ownership of nursing homes
While we largely support the bill, we do have one concern. The licensing moratorium on community residential services and adult foster care may further limit already constrained service options. We are encouraged by the inclusion of exceptions and urge the committee to ensure that any exceptions process is clear, timely, and accessible. Continuity of care cannot be an afterthought—it must be built into the system from the start.
We appreciate the committee’s work to prioritize continuity of care, choice, and safety for Minnesotans with disabilities, and we look forward to continued collaboration.
Joel Runnels, PhD
Legislative Affairs Director
Minnesota Council on Disability
joel.runnels@state.mn.us