On February 26, 2026, the Centers for Medicare and Medicaid Services (CMS) issued a new
Informational Bulletin extending the enforcement date for states to comply with the grievance system requirements, within the Home and Community Based Services (HCBS) Access Rule at 42 CFR §§ 441.301(c)(7), 441.464(d)(5), 441.555(e), and 41.745(a)(1)(iii) (“FFS grievance system requirements”).
The original implementation date was July 9, 2026, and CMS announced they now do not expect to take any enforcement against states until December 31, 2027. CMS notes that the extension is intended to allow additional time to support state compliance, particularly for states that have implemented or plan to implement electronic grievance systems.
Previously, on December 23, 2025, CMS released its first Informational Bulletin related to the HCBS Access Rule, delaying the enforcement date for states to establish Interested Parties Groups until January 1, 2029.