Comment on CMS-2026-2047-0002

Summary: The Minnesota Academy of Family Physicians (MAFP) opposes the proposed interim final rule, arguing that the rigid implementation of Medicaid work requirements creates significant administrative burdens, risks coverage disruptions for vulnerable populations, and places undue responsibility on clinicians. They request that CMS provide states with more flexibility regarding medical frailty exclusions, extend implementation timelines, and clarify that physicians are only responsible for providing clinical documentation rather than making eligibility determinations.