If your family member uses disability waiver services in Minnesota, you may have heard that the state "froze" provider licenses and wondered whether their care is at risk. Most of what's been written about the freeze is aimed at providers and their lawyers. This guide is for families.
The short version: the pause is about new licenses and new services on existing licenses. It's not a list of services being taken away. It can make a provider harder to find in some places, though, so it's worth knowing how it works.
This guide draws on Minnesota Department of Human Services (DHS) pages and Minnesota statutes, checked in November 2026. Rules change and every county works a little differently, so confirm anything about your family member's services with your county or tribal case manager.
A note on where we stand: Midway Homes Adult Care is a licensed 245D provider, so a pause on new licenses limits our new competition. We've stuck to what DHS has published and linked it so you can read it yourself.
What the moratorium is
The temporary 245D licensing moratorium took effect January 1, 2026, with an anticipated duration of 24 months, ending December 31, 2027. "245D" refers to the Minnesota law that licenses home and community-based services for people with disabilities and people over 65. Most of those services are paid for through Medicaid waiver programs such as CADI.
Under the moratorium, DHS has:
- Stopped accepting new applications for 245D licenses
- Stopped adding new service lines to currently licensed providers
- Canceled the applications that were waiting in the queue
The legal authority is Minn. Stat. § 245A.03, subd. 7a, which allows a moratorium of up to 24 months when growth in applications exceeds the determined need for service capacity.
Why DHS did it
In its December 2025 letter to legislators, DHS gave two main reasons:
- Licenses grew much faster than need. Comparing fiscal years 2015–2019 with 2020–2024, the average number of waiver participants rose 24.7%, while active 245D licenses rose 55.3% and new license applications rose 283.3%. In mid-November 2025 there were 2,549 active licenses and 2,314 pending applications.
- DHS couldn't keep up with oversight. The state has committed to reviewing every 245D provider at least once every three years. DHS completed 404 reviews so far in 2025 and said it would need at least 847 a year.
DHS says it will use the pause to review providers that haven't been evaluated in more than three years. If your family member's provider gets a licensing review during this time, that alone doesn't mean something is wrong.
What it means if your family member already has services
Ending current licenses or current services isn't on DHS's list of what the moratorium does. A few details are useful to know:
- A provider can't simply add a service. If your family member's needs change and their provider isn't already licensed for the new service, the provider can't add it without going through the exception process below.
- Licensed providers can still expand what they already do, with one exception. A provider that already has a service on its license doesn't need an exception to open a new facility. Adding a corporate foster care or community residential setting to a license is different, and does go through the exception process.
- A sale doesn't automatically trigger the moratorium. If a provider is bought and its capacity and services don't grow, the FAQ says no exception is needed, though a new license application may be.
The moratorium doesn't protect anyone from the ordinary reasons services end. A provider can still close, lose staff, or give notice. If that happens, or you simply want a change, your family member keeps the right to choose. Our guide on how to change waiver providers in Minnesota walks through the steps.
If you can't find a provider
DHS's position is that statewide capacity has outgrown need, but that doesn't mean every service is easy to find in every town. If you're coming up empty, try these steps in order.
1. Tell the case manager, in writing. Say which service you need, where, and who you've already called. Your case manager coordinates the support plan and is your route to the exception process if it comes to that.
2. Look up who's licensed near you. The DHS Licensing Information Lookup lets you search by county, city or ZIP. Pick the home and community-based services (245D) license type from the list and tick "Active Licenses Only." Then ask each provider directly whether the service you need is on its license and whether it has an opening. DHS currently notes on that site that some newly completed documents aren't posting, so don't rely on it alone.
3. Widen the map if you're able to. The exception standard looks at existing capacity in the county, reservation or region, including surrounding counties, where the person wishes to receive services. Ask whether nearby providers can serve your area.
4. Get free help. Disability Hub MN is a free statewide service, reachable at 1-866-333-2466, Monday to Friday, 8:30 a.m. to 5 p.m.
5. Ask about an exception. If existing providers truly can't meet the need, this is the next step.
How exceptions work
Families and providers can't file an exception directly. DHS only accepts requests from the 245D moratorium liaison at the county, managed care organization or Tribal Nation responsible for the person's waiver case management.
DHS accepts a request in two situations:
- A specific person's service need can't be met within existing licensed capacity in the county, reservation or region where they want services.
- One or more lead agencies identify a regional need for new capacity, based on the needs of several people.
The request has to name a potential provider. The DHS FAQ adds these points:
- Your family member's preferences count. The request form asks for them.
- Timing: DHS expects the exception process to take no more than 60 days. If approved, the application review should take no longer than 45 days, depending on how quickly the provider supplies documents.
- Possible reasons for denial include DHS finding that more providers aren't needed in the area, other ways of meeting the person's needs not having been explored, or the lead agency not having clearly determined that the provider can meet those needs.
- No appeal. There isn't an appeal option for the exception decision itself.
- No guarantee. An exception only lets the provider apply or request the service. It must still meet all licensing requirements, and then enroll with Minnesota Health Care Programs.
Because "other ways of meeting the need" is a reason for denial, your written record of who you called and what they said can help your case manager.
If your family was planning to start its own provider
Some families consider setting up their own licensed agency to care for a relative. During the moratorium, DHS isn't accepting new applications outside the exception process. DHS's FAQ tells anyone interested in a 245D license to start with the moratorium liaison in their county. Ask your case manager about other options too. Our respite care guide notes that some individual caregivers can be excluded from 245D licensing, and your case manager can explain when that applies.
What happens after 2027
December 31, 2027 is an anticipated end date. In its letter to legislators, DHS said it would work on post-moratorium strategies to better match new applicants with statewide service needs, and would provide updates to the legislature. For questions the case manager can't answer, DHS's moratorium contact is licensemoratorium.dhs@state.mn.us, and its 245D licensing help desk is 651-431-6624, Monday through Friday, 8:00 a.m. to 4:00 p.m.
Looking for a provider now?
When you're comparing the providers that are available, our questions to ask a 245D provider can help you tell them apart.
Midway Homes Adult Care LLC is a Minnesota 245D-licensed provider serving Ramsey, Hennepin, Dakota, Scott, Washington, Chisago and Pine counties. If you're having trouble finding services, or you want help making sense of what you've been told, call 612-416-8555. If we're not the right fit, we'll tell you.