Health Center Regulatory Issues, Health Center State Policy

CMS Issues Guidance on Community Engagement and Work Requirement Proposals for Medicaid

Today CMS published its much anticipated federal policy guidance (SMD: 18-002, see NACHC summary here) reiterating its support and describing considerations for states with an interest in pursuing Section 1115(a) Medicaid waivers to implement work and/or community engagement requirements for Medicaid.

This effort began last year with a letter from then-Secretary Price and CMS Administrator Seema Verma outlining the Administration’s priorities for the Medicaid program. In November 2017, Verma announced (in remarks to the National Association of Medicaid Directors) that CMS would approve states’ requests to implement work and/or community engagement activities as requirements for participation in their Medicaid programs. We have seen an increasing number of states request (or prepare to request) (see KFF’s Section 1115 Medicaid waiver tracking page) that the federal government approve their Section 1115 Medicaid waiver proposals to add work-related and/or “community engagement” requirements to their Medicaid programs. Barring an exception or exemption, these proposals require all able-bodied adults on Medicaid to participate in some form of community engagement to qualify for and receive Medicaid coverage.

NACHC has and will continue to provide direct support to partners at state Primary Care Associations, HCCNs and health centers to monitor, assess and respond to all waiver proposals, including those which seek to implement community engagement and/or work-related requirements. This includes continuing our work with national partners to ensure that Medicaid beneficiaries, 1 in 6 of whom are health center patients, do not lose their access to care as a result of waiver proposals. All partners are encouraged and expected to continue efforts to remain engaged with policymakers and provide meaningful input, comments, feedback and recommendations throughout the waiver process to their states and CMS, from application to implementation and evaluation. The hope is that policymakers will take into account the full body of input from the public to ensure the efficacy and dramatically reduce the potential harm of these proposals.

NACHC will provide further updates as the situation develops. In the interim, NACHC will look forward to providing continued support and will also work to ensure that policymakers are aware of the potential impact, positive or negative, that waiver proposals may have on health centers and the patients they serve.

Questions regarding CMS’ policy guidance should be directed to state@nachc.org.

Susan Sumrell contributed to this blog post. 

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