AHA requests CMS reconsider provisions within Medicaid community engagement rule

The AHA July 31 provided comments to the Centers for Medicare & Medicaid Services on its interim final rule on Medicaid community engagement requirements. To be eligible for or maintain Medicaid coverage, the rule requires certain adults to complete 80 hours per month of “qualifying activities,” such as employment, education, community service or participation in a work program, or meet equivalent income thresholds. The AHA shared concerns about two provisions that it said could increase procedural disenrollments and undermine coverage and access to care if left unchanged.  

The AHA said CMS’ definition of medical frailty adds an overarching functional impairment requirement that will create barriers to coverage for individuals with serious or complex medical conditions. The second provision involves CMS’ approach to good-faith effort exemptions, which conditions approval on a showing of “extraordinary or severe barriers.” The AHA said it risks pressuring states to implement the requirements before they are operationally ready, increasing the likelihood that individuals lose coverage for procedural rather than substantive reasons. The AHA urged CMS to reconsider both policies and extend greater flexibility to states working to implement the requirements.