On December 8, The Centers for Medicare and Medicaid Services (CMS) issued initial, new guidance to states to inform implementation of the new Medicaid community engagement provisions (aka: work reporting requirements) included in H.R. 1. The new law includes multiple sweeping changes to the Medicaid program, with more guidance expected to follow. In issuing this initial guidance, CMS officials outlined four principles guiding policy development:
1) connect members to work and community;
2) offer states flexibility;
3) promote alignment with existing requirements for other programs such as SNAP and TANF; and
4) protect taxpayers.
What's new?
The guidance focuses primarily on restating requirements from H.R. 1 across key areas of focus with some limited new pieces of operational direction: see our new blog post for detailed information.
What's the takeaway?
The guidance adds some new insight, including CMS interpretations related to compliance verification, potential sources of “reliable information” for those verifications, and the role of managed care organizations (MCOs).
Now what?
CMS is expected to issue additional guidance, particularly with more detailed instructions for state operationalization. H.R. 1 requires CMS to issue an interim final rule (IFR) by June 1, 2026, though it is not yet clear whether outstanding questions will be addressed through that final rulemaking or through further subregulatory guidance beforehand. We will share more information as it becomes available.
