Guides · Minnesota
The 245D licensing moratorium, in plain language.
Written for operators and the people advising them. What DHS actually paused, what still works, how the exception path runs, and why the next two years favor the providers who already hold a license.
What is paused, and what is not
- Paused: new 245D license applications — DHS is not accepting them, and applications pending on January 1, 2026 were cancelled.
- Paused: adding service lines to an existing 245D license (for example, a basic-support licensee adding intensive services).
- Not paused: operating under an existing license — serving new clients, hiring staff, and renewing normally.
- Not paused: licensure reviews. DHS cited review-backlog staffing as a reason for the pause; existing providers should expect reviews to continue and tighten.
- Not paused: changes of ownership follow their own DHS process — talk to your licensor before assuming either way.
How the exception process actually works
Providers do not file exceptions. The request comes from the lead agency responsible for a person’s waiver case management — a county, a managed care organization, or a Tribal Nation — and it moves through a designated moratorium liaison that each lead agency registered with DHS. There are two accepted grounds: a specific person whose assessed service need cannot be met within existing licensed capacity in the county, reservation, or region; or a regional capacity need documented by one or more lead agencies together. In both cases, the lead agency identifies the provider it wants to meet the need as part of the request.
Practically, that means a would-be provider’s only move is relationship work: be known to county case managers and MCO care coordinators as the operator they would name when a real gap appears. The details and current forms live on DHS’s temporary moratorium exceptions page and its FAQ.
If you already hold a 245D license, the window is yours
A two-year pause on new entrants is a protected market for the roughly fifteen hundred agencies already licensed. The operators who use it well will do three things: run clean licensure reviews (the review backlog was a stated reason for the pause — scrutiny is not going down), keep documentation and EVV compliance tight as enforcement steps up, and take on the client growth that would otherwise have gone to new entrants. The ones who lose the window will spend it reconciling spreadsheets.
Common questions
Can I apply for a new 245D license right now?
No. DHS stopped accepting new 245D license applications on January 1, 2026, and the pause is expected to run about 24 months, through December 31, 2027. Pending applications were cancelled, and existing license holders cannot add new service lines during the moratorium.
Is there any way to get a 245D license during the moratorium?
Only through an exception request — and providers cannot file one themselves. The request must come from a lead agency (a county or managed care organization) or a Tribal Nation, through their designated moratorium liaison, either for a specific person whose service need cannot be met by existing licensed capacity, or for a documented regional capacity need. The lead agency names the provider as part of the request.
Does the moratorium affect my existing 245D license?
Your existing license and the services already on it are unaffected — you can keep operating, serving new clients, and hiring. What you cannot do is add additional service lines to the license while the moratorium is in effect.
Why did DHS pause 245D licensing?
DHS cited a 283% increase in license applicants alongside a backlog in the triennial review process — more providers than the review system could oversee, in a market DHS describes as oversupplied in some service types.
Where ClientCentric fits (the vendor part, clearly labeled)
ClientCentric is operations software built under 245D — scheduling, visit documentation, EVV workflows, staff time, client records, and append-only audit history in one system. For license holders using the moratorium window to grow, the pitch is simple: growth without documentation debt, and a system a licensure reviewer can be walked through.
Written and maintained by the ClientCentric team from the working product. Last reviewed . Sources: Minnesota DHS temporary moratorium exceptions pages and DHS's December 2025 letter to legislators. This is operational guidance, not legal advice — confirm specifics with your licensor or counsel.