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1915(c)(11) Waiver Services and Solutions

Expand home and community-based services (HCBS) for aging adults and people with disabilities — before they reach an institutional level of care. Public Consulting Group’s Aging & Disability Services experts are here to help states plan, design, model, and submit 1915(c)(11) waivers with confidence.

Trusted Expertise in Waiver Design and HCBS Expansion

Starting July 2028, CMS is expected to approve a new pathway to Medicaid HCBS coverage for individuals who don’t yet meet institutional level-of-care criteria. Funding to support states pursuing these waivers begins in the federal fiscal year 2027. In a July 2026 webinar, CMS indicated they planned to distribute this funding in the next few months.

States face a familiar challenge: building a compliant, financially sound waiver program that meets CMS requirements, remains operationally viable after launch, and meets the needs of participants, stakeholders, providers, and families.

Public Consulting Group (PCG) designs, drafts, and implements HCBS waivers for state Medicaid, Aging, and Developmental Disabilities agencies. Our team recently partnered with a state to design a new 1915(c) waiver and received approval under the current administration in three months. We did so by leveraging deep expertise in both new waiver development and amendment processes.

We help states:

  • Assess whether and how new waiver programs can support their priorities
  • Define needs-based eligibility criteria and covered services
  • Establish provider qualifications and participant safeguards
  • Prepare for CMS review — including cost neutrality and annual reporting
  • Navigate the CMS review process from submission to approval

Our approach combines HCBS policy expertise, stakeholder engagement, waiver application development, rate and cost modeling, assessment design, and analytics. This approach allows states to assess options before submission, understand impacts on existing waivers and waitlists, and build the infrastructure to sustain the program long after approval.

Click here to learn more about the new 1915(c)(11) waiver.

1915(c)(11) Waiver Services with PCG

  • Population, eligibility, and service package design
  • Cost benefit analysis
  • Assessment and screening tool development
  • Stakeholder engagement and advisory groups
  • Cross-waiver business process review
  • Communications, outreach, and training
  • Provider qualifications and monitoring design
  • Rate studies and cost neutrality analysis
  • Federal reporting, dashboards, and CMS readiness

Comprehensive Waiver Development for Medicaid, Aging, and Developmental Disabilities Agencies

For the first time, states can use a standalone Medicaid HCBS waiver to reach individuals who need earlier home and community-based support, before they meet institutional-level-of-care criteria. PCG helps states evaluate target populations, service options, fiscal impact, and operational requirements to move from concept to CMS-ready submission.

Ready to develop a 1915(c)(11) waiver with PCG? Click here to get started.

Why Partner with PCG

PCG provides practice implementation support, helping states design HCBS programs that are compliant, financially sound, and responsive to community needs. PCG has expertise in:

  • CMS-ready waiver design: Waiver programs and applications aligned with current CMS requirements and state policy goals.
  • Eligibility and assessment design: Dual eligibility tracks for institutional level of care and the pre-institutional group, screening tools, individual budgets, and tiering approaches.
  • Stakeholder-centered planning: Advisory groups, town halls, and focus groups that align agencies, providers, participants, families, and advocates.
  • Fiscal and waitlist modeling: Utilization, waitlist, provider capacity, and population data to model costs and impacts before submission.
  • Operational readiness: Provider qualifications, person-centered planning, monitoring, safeguards, and quality assurance.
  • Reporting and analytics infrastructure: Dashboards and data solutions built for federal reporting and ongoing CMS readiness.

Frequently Asked Questions

What is a 1915(c)(11) waiver? A 1915(c)(11) waiver is a new type of Medicaid Home and Community-Based Services (HCBS) waiver that allows states to cover aging adults and people with disabilities who do not yet meet institutional-level-of-care criteria. It’s designed to reach individuals earlier, before their needs escalate to the point of requiring institutional care.

When can states start submitting 1915(c)(11) waiver applications? CMS is expected to begin approving 1915(c)(11) waiver applications starting in July 2028. Funding to support states pursuing these waivers becomes available in the federal fiscal year 2027. In a July 2026 webinar, CMS indicated they planned to distribute this funding in the next few months.

How is a 1915(c)(11) waiver different from a traditional 1915(c) waiver? Traditional 1915(c) waivers require participants to meet an institutional level of care. A 1915(c)(11) waiver removes that requirement, letting states serve individuals with lower-acuity needs through a standalone HCBS waiver.

How long does it take to design and implement a 1915(c)(11) waiver? Waiver design, stakeholder engagement, and CMS submission preparation typically take 18–24 months. States planning for the July 2028 approval window should begin strategic planning now.

What does the 1915(c)(11) waiver process involve? States generally need to define needs-based eligibility criteria, design covered services, set provider qualifications, build assessment and screening tools, model costs and waitlist impacts, and prepare documentation for CMS review — including cost neutrality and reporting requirements.

Who can help states design and submit a 1915(c)(11) waiver? Public Consulting Group (PCG) supports state Medicaid, Aging, and Developmental Disabilities agencies through the full waiver lifecycle — from eligibility design and stakeholder engagement to rate modeling, CMS submission, and post-approval reporting infrastructure.

Ready to plan your state’s 1915(c)(11) waiver strategy?

July 2028 may feel far off, but waiver design and stakeholder engagement typically take 18–24 months. Contact PCG at [email protected] or fill out the contact form below to start planning your state’s HCBS expansion, CMS readiness, and long-term implementation roadmap.

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