HSAG Round 8 – and already there are issues!

April 09, 2026

Q32 in the HSAG review asks “Does the provider have policies and procedures that address HCBS Rights?”

A ‘Yes’ rating is indicated when the provider has a policy and procedure that addresses HCBS rights, includes a process for reviewing the policy/procedure with individuals and includes language regarding the individual’s right to have private electronic communication (email, text, phone call, etc.).

A ‘No’ score is indicated when a provider does not have a policy and procedure that addresses all requirements of the HCBS rights or does not include the process for reviewing the policy/procedure with individuals.

A ‘N/A’ rating is indicated when the provider service type under review is case management, respite, or Independent Living Support.”


This seems to exceed the requirements of the HCBS requirements for any “policy” and here are the actual requirements (Chapter 2 of the Manual) and draft policies published to meet the requirements of HCBS.

DD Waiver Manual – Chapter 2  – page 34


Provider Do’s and Don’ts


Sample Rights Policies