Medicaid Program: Community Engagement Requirement for Certain Individuals

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.

Brad Christensen, Administrator of A Gentle Touch Home Care, opposes the proposed administrative requirements for Medicaid recipients. He argues that the new application and review processes will create significant barriers for medically frail clients and impose an unfunded administrative burden on home care providers.

Peridom Insights, a health equity firm, opposes the proposed Medicaid community engagement requirements because they believe the increased administrative burden will lead to procedural disenrollment for eligible individuals. They argue that complex documentation and reporting requirements will disproportionately affect marginalized communities, individuals with behavioral health conditions, and those with limited digital literacy.

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.

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.

The Maine Cancer Foundation opposes the proposed rule because it creates administrative burdens and potential barriers to healthcare coverage for individuals with cancer and chronic diseases. They argue that states should instead rely on existing medical records and claims data to verify eligibility and ensure continuity of care for patients.

The commenter, a private individual living with cancer and disabilities, opposes the proposed community engagement requirements for Medicaid recipients. They argue that the new criteria would create unnecessary and cruel hurdles for vulnerable people seeking essential healthcare funding.

The commenter, a private individual living with cancer and disabilities, opposes the proposed community engagement requirements for Medicaid recipients. They argue that the new criteria would create unnecessary and cruel hurdles for vulnerable people seeking essential healthcare funding.

LaDawn Tate, a person living with HIV and a member of Positive Women's Network–USA PWN-USA, opposes the proposed rule because it creates unnecessary administrative barriers and paperwork. She argues that these requirements could lead to interruptions in life-saving healthcare and urges the agency to withdraw or substantially revise the rule.