AAMC Statement on Centers for Medicare and Medicaid Services Work Requirements Interim Final Rule

• Press Release

AAMC Chief Health Care Officer Jonathan Jaffery, MD, MS, MMM, FACP, issued the following statement on a new rule proposed by the Centers for Medicare and Medicaid Services:

"The Centers for Medicare and Medicaid Services' (CMS) long-awaited rule on Medicaid work requirement implementation imposes conditions that extend beyond those included in the statute. The One Big Beautiful Bill Act (OBBBA) explicitly grants states flexibility to define certain exclusions for some of Medicaid's most vulnerable patients. However, the rule goes beyond the statutory requirements by limiting the ability of states to allow Medicaid enrollees to self-attest to meeting work requirements and by narrowly defining the medical frailty exemption.

AAMC-member health systems and teaching hospitals, medical schools, and their affiliated physician faculty demonstrate their commitment to caring for Medicaid patients every single day by providing nearly a third of all Medicaid inpatient care, underscoring the indispensable and outsized role they play in meeting the needs of our most vulnerable populations and communities. The interim final rule will impede the delivery of this care and will increase coverage losses among individuals due to procedural barriers, resulting in increased levels of uncompensated care and straining hospital resources used to treat these often-complex patients.

The AAMC calls on CMS to modify the provisions that go beyond the statutory framework of the OBBBA, which will maintain states' flexibility to manage their Medicaid programs and minimize unnecessary coverage losses and administrative burden. We stand ready to collaborate with CMS to achieve our shared goals of preserving access to care for Medicaid enrollees while minimizing burden on states, providers, and patients."