Partnership for Medicaid: Preserve Medicaid Access in Community Engagement Rule

In a July 31 letter to the Centers for Medicare & Medicaid Services (CMS), the Partnership for Medicaid urged the agency to withdraw or clarify several proposals in the Medicaid Community Engagement Requirements for Certain Individuals interim final rule that would reduce access to care.

The Partnership for Medicaid is a nonpartisan, nationwide coalition of organizations representing clinicians, health care providers, safety net health plans, and counties, which works to preserve and improve the Medicaid program. America's Essential Hospitals signed on to this letter along with 14 organizations.

The letter shares the partnership's concerns about the community engagement requirement implementation that could lead many eligible Medicaid beneficiaries to lose coverage. Specifically, the partnership asked CMS to:

• Clarify that waivers covering a population of likely excluded individuals are excluded entirely from community engagement requirements, not individually
• Clarify that when an individual is working for pay using supported employment services, such work would qualify as hours of work, not a work program
• Remove the extra-statutory requirement that individuals who are medically frail or otherwise have special health care needs must also demonstrate that they are significantly impaired in complying with the community engagement requirement
• Account for data sharing and ex parte decision limitations when confirming medical frailty
• Expand the groups that do not need to be reverified and clarify where states may not reverify unchanged statuses
• Not limit self-attestation beyond congressional intent
• Align the look-back period for short-term hardship exceptions with congressional intent and make an exception when a dependent needs inpatient care in the local community

Contact Director of Policy Rob Nelb, MPH, at [email protected] or 202.585.0127 with questions.