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Dates and Deadlines

All states must submit to CMS a plan for transitioning their current HCBS system into compliance with the new rule by March 17, 2015. States submitting a 1915(c) waiver renewal or amendment before March 17, 2015 must include a transition plan in that submission. States then have 120 days from that submission date to submit a transition plan for the remainder of their HCBS system.

Vermont does not have an HCBS waiver or state plan benefit up for renewal before the March 17, 2015 deadline. The state has until March 17, 2015 to submit a transition plan to CMS. For more information visit

Vermont operates its Medicaid system entirely through two 1115 waivers, including HCBS through the Vermont Choices for Care waiver. CMS has indicated that HCBS delivered through 1115 waivers must be compliant with the rule. Advocates are still awaiting guidance from CMS how they will implement and enforce this requirement.

Instead of Vermont having to submit a statewide transition plan (STP), CMS is accepting what is called a Comprehensive Quality Strategy Plan (QSP). Vermont is required to create this plan as part of their Global Commitment to Health 1115 waiver. CMS is holding QSP to the same standards as the STP, including public comment periods and summaries. 

August 24, 2018 NEW CMS’ Additional Feedback for Final Approval

Open Comment Period closes March 20, 2020

State DocumentsBack to TOP

The Vermont Agency of Human Services (AHS) gives notice that the DRAFT Global Commitment to Health (GC) waiver Comprehensive Quality Strategy Plan (CQS), required by the Centers for Medicaid and Medicare Services (CMS) will be available for public review and comment for a period of 30 days beginning on 08/01/2015 and ending on 08/31/2015.

Comments from Vermont DD Council to State  – August 31, 2015

Comment from Vermont Legal Aid to State – August 31, 2015

Vermont Comprehensive Quality Strategy Plan PowerPoint

Vermont Global Commitment to Health PowerPoint

Letter to Vermont from CMS approving request to amend section 1115 Global Commitment to Health; effective from January 30, 2015 through December 31, 2016 unless otherwise specified.

Vermont Global Commitment to Health Comprehensive Quality Strategy Plan: Timeline

Vermont Global Commitment to Health Comprehensive Quality Strategy Plan: Outline

Vermont Global Commitment to Health Comprehensive Quality Strategy Plan: Driver Diagram 

Comprehensive Quality Strategy Plan DRAFT sent to CMS – July 6, 2015

Final Comprehensive Quality Strategy Plan sent to CMS – September 15, 2015

Clarifications and/or Modifications required for Initial Approval (CMIA): This letter notifies states that public comment, input and summary requirements are met, but CMS has identified issues that must be resolved in the Statewide Transition Plan (STP) prior to initial approval. CMS sent this letter to Vermont on Oct 29, 2015

 CMS sent a revised Clarifications and/or Modifications required for Initial Approval (CMIA) to VT on Dec 29, 2015

VT receives Initial Approval with Milestones and a Resubmission Date. This letter is the communication CMS sends to the state notifying the state that public comment, input and summary requirements are met, the STP is sufficient, but systemic and/or site-specific assessments are not yet completed.  The response to the state will vary dependent on whether the state has or has not identified settings that are presumed to have institutional characteristics and any information the state may wish CMS to consider under the heightened scrutiny process. December 5, 2016

ResourcesBack to TOP

Department of Vermont Health Access Public Notice Website

Global Commitment to Health 1115 Fact Sheet

NewsBack to TOP

More to come

State PartnersBack to TOP

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