Medicaid Program: Community Engagement Requirement for Certain Individuals

Lane Independent Living Alliance opposes the proposed rule, arguing that the "medically frail" definition adds unauthorized functional tests that could exclude eligible individuals with disabilities. They request that CMS align the definition with statutory categories, simplify verification processes for those with poorly documented disabilities, and remove the 80-hour threshold for non-resident caregivers.

The National Partnership for Healthcare and Hospice Innovation (NPHI) supports the proposed rule but urges CMS to provide explicit guidance ensuring that hospice and palliative care patients are automatically exempted from community engagement requirements. They argue that these medically vulnerable populations should not face administrative burdens or risk losing coverage due to their inability to meet engagement obligations.

The American Association for the Study of Liver Diseases (AASLD) opposes the interim final rule because it sets an unnecessarily narrow standard for the medical frailty exemption for Medicaid beneficiaries with serious medical conditions. They argue that requiring patients to demonstrate an inability to satisfy community engagement requirements—rather than just having a qualifying diagnosis—creates administrative burdens and risks interrupting essential care for those with chronic liver disease.

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.

The American College of Physicians (ACP) opposes the proposed interim final rule, arguing that the "medically frail" definition is too narrow and will create significant administrative burdens for physicians and states. They urge CMS to base eligibility on clinical risk rather than functional ability, maximize automated data verification, and provide states with greater implementation flexibility.

VibezBombz, a behavioral health engagement organization, supports the proposed action but argues that the current implementation plan lacks a viable way to verify functional impairment for individuals with substance use disorders or mental illnesses. They urge CMS to recognize non-clinical, peer-delivered functional-capacity attestations as an acceptable verification method to ensure these populations are not procedurally disenrolled.

The National Association of Benefits and Work Incentives Specialists (NABWIS) opposes the proposed community engagement requirements for Medicaid participants, arguing that the rules create an unreasonable administrative burden on states and vulnerable individuals. They specifically highlight concerns regarding unclear definitions of disability, barriers for homeless individuals and veterans, and the potential for people to lose lifesaving coverage due to systemic delays in accessing medical care.

The Health Foundation for Western & Central New York opposes the proposed Medicaid community engagement requirements, arguing they will negatively impact caregivers of older adults and individuals with chronic medical conditions. They request broader definitions for exemptions and state-level judgment for short-term hardships to prevent loss of coverage for vulnerable populations.

Team Titin, Inc., a nonprofit serving people with titin-related muscle and heart disorders, opposes the proposed community engagement requirements in CMS-2454-IFC. They argue the rule creates risks of Medicaid coverage loss for individuals with complex, chronic conditions and their caregivers due to narrow frailty standards and burdensome documentation requirements.

Indivior Pharmaceuticals, Inc. opposes the "significant impairment" requirement in the proposed rule, arguing it unnecessarily narrows the medical frailty exemption for individuals with substance use disorders (SUDs). The company argues that this requirement could disrupt Medicaid coverage for people in recovery and recommends that a documented SUD diagnosis alone should be sufficient to qualify for the exemption.