If your organization provides services through a New York Social Care Network (SCN), the latest program guidance warrants immediate attention. Version 9 of the SCN Operations Manual, released August 12, 2026, introduces significant changes affecting household nutrition services, restricts several practices used by Community-Based Organizations (CBOs), including gift cards and certain website-based data collection, and adds provider oversight requirements.
Implementation is complicated by conflicting dates. Three different dates appear across two governing documents, while the Operations Manual itself does not readily identify an effective date. Nevertheless, CBOs should promptly assess what operational, contractual, and billing changes may be required, particularly given the potential for claim denials, audit findings, and program participation consequences.
CIN Compliance
One important change is that external health-related social needs (HRSN) provider websites may no longer collect Medicaid member IDs or Client Identification Number (CINs). At the same time, however, household nutrition billing rules require CBOs to use the primary eligible member’s CIN when submitting claims with the TT modifier, which is the HCPCS Level II modifier that indicates nutrition services were provided to support additional individuals in the same household. Some CBOs have reported that this restriction complicates their existing workflows for obtaining the member identifiers necessary to generate compliant invoices. The net effect is that CBOs are processing more PHI through more systems, under tighter controls, with fewer informal collection methods available. For CBOs that were not previously subject to HIPAA as covered entities or business associates, this combination of requirements represents a significant operational lift requiring updated privacy policies, workforce training, access controls, and breach response planning.
HIPAA Compliance
Based on our analysis of the Operations Manual, the template SCN Master Services Agreement (MSA) and Business Associate Agreement (BAA) framework, and applicable HIPAA regulations, CBOs participating in the SCN program must maintain a functioning set of HIPAA compliance policies, including documented requirements for access controls, breach notification, workforce training, PHI disclosure tracking, and data retention and destruction.
For CBOs that were not previously subject to HIPAA as covered entities or business associates, these requirements can represent a substantial operational lift. We recommend that CBOs have counsel assess whether existing policies, procedures, and documentation satisfy their current obligations. We are available to assist with policy drafting, staff training frameworks, breach-response planning, and subcontractor flow-down agreements.
Implementation Date Uncertainty
The Operations Manual is dated August 12, 2026, but does not appear to state a clear operational effective or implementation date. Revised SCN Fee Schedules identify an August 17, 2026 “effective date” and a separate September 1, 2026 “implementation date,” without clearly explaining the operational distinction. In addition, revised regional HRSN Fee Schedules issued by SCNs contain an August 17, 2026 effective date and a separate September 1, 2026 implementation date without further explanation.
Revised Fee Schedules
The revised schedules list updated per-household reimbursement caps for nutrition services. Our understanding at this time is that the updated caps likely apply to services initiated on or after the August 17 effective date. We are seeking confirmation from SCN Lead Entities regarding what, if anything, changes on September 1 and how nutrition services previously authorized for household members under Version 8 must transition to Version 9. Because Fee Schedules are issued by SCN region, CBOs should confirm the dates applicable to their regional schedule.
Nutrition Services — Significant New Requirements and Increasing Compliance Risk
Household members and Service 3.2.
Non-Enhanced household members may no longer receive Service 3.2 (Medically Tailored Meals or Clinically Appropriate Meals). They must instead be referred to Service 3.3 (Food Prescriptions) or Service 3.4 (Pantry Stocking), unless the SCN Lead Entity approves an exception in writing.
Household eligibility remains available in limited circumstances.
Household members may receive nutrition support where the primary eligible member is a pregnant/postpartum person or high-risk child under 18. Household members must be enrolled in Medicaid Managed Care and have an unmet nutrition HRSN identified through screening, but need not independently satisfy Enhanced Population or clinical criteria. Billing uses the primary member’s Medicaid CIN with the TT modifier.
Anti-stacking rule.
Once the primary eligible member exhausts the approved service duration, another eligible household member may not apply for the same Enhanced HRSN service to extend services for the household.
New voucher controls.
Vouchers must be individually assigned, non-transferable, and traceable to the eligible member. Gift cards are expressly prohibited. Voucher mechanisms must include controls to prevent unauthorized use and permit monitoring. The Manual states these may include SKU-level controls where technically feasible, member authentication such as a PIN, restricted merchant category codes, and transaction-level reporting. Voucher administrators and providers must maintain transaction-level records showing that benefits were redeemed for food consistent with the approved food plan.
Meals and food boxes for households with children must include age-appropriate serving sizes reflecting children’s nutritional needs..
New household-level caps.
The Fee Schedule establishes per-household caps for household sizes 2–10 for Food Prescriptions (3.3) and Pantry Stocking (3.4). RDNs/CDNs must confirm household members based on documentation collected, reviewed, and approved by the Social Care Navigator before services begin. It has also now been clarified that nutrition assessments and progress notes must be uploaded to the SCN IT Platform; local-only retention is no longer sufficient.
VendRep Certification
Provider Responsibility Review by October 1, 2026.
HRSN Service Providers receiving $100,000 or more over the waiver period must complete the provider responsibility review. The threshold includes CBO capacity funds and service payments combined; healthcare systems are excluded. VendRep recertification is required every six months online or annually on paper. Failure to complete the review, or adverse findings, may result in a performance improvement plan (“PIP”) or termination.
SCN Lead Entities must contract with every MCO in New York State by November 13, 2026, expanding the requirement from regional to statewide contracting.
Given the complexity of Version 9 and the evolving nature of OHIP and SCN Lead Entity guidance, our understanding of these requirements will continue to develop. We may issue updated alerts as further clarification becomes available. These initial observations are intended to support timely compliance planning.
Should you have any questions regarding the above or wish to have your organization’s services evaluated for compliance with applicable laws, please contact the authors, the Garfunkel Wild attorney with whom you regularly work, or contact us at [email protected].