What You Need to Know: North Dakota's New Medicaid Provider Revalidation Strategy

Statement from Kirsten Dvorak, Executive Director, The Arc of North Dakota

What Is Happening

Effective June 5, 2026, North Dakota Health and Human Services launched a two-year Medicaid Provider Revalidation Strategy. This was developed in response to a federal request from the Centers for Medicare and Medicaid Services (CMS).

The strategy targets three provider categories:

• Qualified Service Providers (QSPs) — individuals and agencies providing in-home and community-based care

• Non-Emergency Medical Transportation (NEMT) providers

• 1915(i) providers — those delivering supported employment, peer support, community transition, housing support, and related services.

Revalidation runs through June 2028. Going forward, these providers will move from a five-year to a three-year revalidation cycle. New requirements include mandatory site visits, annual competency attestations, and new National Provider Identifier (NPI) requirements for provider types previously exempt.

Our Concern: 1915(i) and the Autism Community

Of everything in this strategy, The Arc of North Dakota is most concerned about the impact on 1915(i) providers and the people they serve.

1915(i) covers services that help people live, work, and participate in their communities — things like peer support, job coaching and employment support, help at home, community transition services, and supported education. For many individuals in the autism community who qualify for Medicaid but do not meet the criteria for other disability programs, 1915(i) is their primary — and sometimes only — pathway to these supports.

The 1915(i) program is already fragile. Provider participation in North Dakota is low because the program is administratively complex and difficult to manage. Adding mandatory site visits, annual attestations, and higher compliance requirements to an already burdened program risks pushing more providers out entirely. If that happens, individuals who depend on 1915(i) — particularly those in the autism community — will have few, if any, alternatives.

The QSP Moratorium

The strategy also includes a proposed enrollment moratorium on QSP agencies in Cass and Burleigh counties. The Arc of North Dakota understands the state's concern and is not opposing this action. We are simply asking that implementation be carefully monitored to ensure there are no unintended consequences for individuals and families in those communities who rely on these services.

The 10% Budget Cut

This revalidation strategy does not exist in isolation. Governor Kelly Armstrong has directed each department within DHHS to identify 10% in cuts across their programs for the next biennium budget. Every department — including those that fund and oversee services for people with intellectual and developmental disabilities — must determine where those reductions will come from.

New compliance requirements and significant budget cuts are landing on the same system at the same time—that combination poses real risks to the programs and the people who depend on them.

The Arc of North Dakota's Position

Governor Armstrong has stated that this strategy is intended to strengthen the program for recipients and that the vast majority of providers operate in good faith. We hold that statement as the standard by which implementation will be measured.

The Arc of North Dakota is concerned that the combination of increased compliance requirements and 10% budget reductions across DHHS departments will produce consequences that undermine that goal. When 1915(i) providers exit the program due to administrative burden, individuals lose access. When DD program budgets are reduced while compliance costs rise, something gives — and it is rarely the compliance requirement.

We will monitor implementation closely and continue to raise concerns on behalf of the IDD population across North Dakota. We urge policymakers to track not only whether providers complete revalidation but also whether individuals with intellectual and developmental disabilities can still access the services they need.—both matter.