CMS Approves First Statewide Transition Plan

The Centers for Medicare & Medicaid Services (CMS) has granted Tennessee final approval of the state’s Statewide Transition Plan (STP), marking the first such approval to date.  Final approval was granted, according to CMS, “because the state completed both its systemic assessment and its site-specific assessment, included the outcomes of both assessments in the STP, outlined remediation strategies to rectify issues that both assessments uncovered, and laid out its heightened scrutiny, ongoing monitoring and relocation processes.”

CMS points out that “the state has laid out a comprehensive validation process for the site-specific assessment involving managed care organizations, the Department of Intellectual and Developmental Disabilities (the Operational Administrative Agency for the state’s waivers), and the Bureau of TennCare.” The STP includes “a summary of the outcomes of the site-specific assessments and an overview of, and timeline for, the plans for site-specific remediation,” as well as “a detailed plan for identifying settings that are presumed to have institutional characteristics, a plan for evaluating and applying for heightened scrutiny, a plan for relocating beneficiaries in the event that a setting cannot or will not come into compliance with the federal requirements, and a plan for ongoing monitoring of continued compliance.”

According to the agency, Tennessee will need to provide quarterly written updates, and participate in quarterly phone discussions with the CMS team to review the state’s progress in implementing the STP. In addition, the state must work collaboratively with CMS to identify any areas that may need strengthening with respect to the state’s remediation, relocation, and heightened scrutiny processes as they implement each of the key elements of their state transition plan.

In the approval letter, CMS notes that the “approval of a STP solely addresses the state’s compliance with the applicable Medicaid authorities” and “does not address the state’s independent and separate obligations under the Americans with Disabilities Act, Section 504 of the Rehabilitation Act or the Supreme Court’s Olmstead decision.”

FMI: The CMS approval letter can be found at The plan itself can be read at