By Patricia Nellius, Executive Director, Federation for Children with Special Needs
Dear Community:
The Centers for Medicare & Medicaid Services (CMS) has released an Interim Final Rule (IFR) that provides guidance to states on implementing the new mandatory Medicaid work reporting requirements under HR1.
What’s at Stake
The IFR includes policies that will likely lead to even greater Medicaid coverage losses. These changes are expected to make implementation more difficult for states and increase the likelihood of Medicaid coverage losses. Two major changes include:
- Narrows the medical frailty exemption. The IFR limits HR1’s exemption to people deemed unable to work, putting those with serious or complex conditions at risk of losing coverage.
- Increases documentation requirements. States must reverify medical frailty annually, and most enrollees will lose the option to self-attest starting in 2028, adding burdens for patients, providers, and states.
What You Can Do
CMS is taking public comment on this IFR until July 31. This comment period is an opportunity to engage policymakers, partners, and the press, and educate them about the dangers this rule poses to people with Medicaid coverage. We encourage you to submit comments before July 31, 2026, and share:
- How the IFR may create unnecessary barriers to maintaining coverage.
- Concerns about the medical frailty definition and documentation requirements.
- The challenges states, providers, and beneficiaries will face implementing these requirements by January 1, 2027.
- The potential for increased coverage losses and administrative burden.
Whenever possible, make your comments personal and specific. Unique comments are more impactful than copied template responses. Even though CMS can move forward with the rule while comments are under review, public feedback helps demonstrate the real-world impact these changes could have on individuals, families, providers, and communities.
Thank you,
Patricia Nellius
Executive Director
Federation for Children with Special Needs
Read the rule and submit a comment here: Medicaid Program: Community Engagement Requirement for Certain Individuals