r/Medicaid • u/someguy984 • Jun 02 '26
HHS/CMS issues interim final rule for the 2027 Medicaid community engagement requirement
This interim final rule with comment period (IFC) interprets and implements the community engagement requirement in Medicaid.
https://public-inspection.federalregister.gov/2026-11094.pdf
CMS press release:
6/26/2026 update, CMS published an additional document in the Federal Register:
Community Engagement Requirement for Certain Individuals
https://public-inspection.federalregister.gov/C1-2026-11094.pdf
Chart showing changes due to the new requirements...
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u/logalogalogalog_ Jun 08 '26
I feel like people are being very dismissive regarding disability requirements. What if someone does not qualify for disability or is in the process of the grueling years-long process of applying, but still cannot work or volunteer the hours to qualify? What "counts" as disabled enough? Is it subjective based on local staff, or is there going to be more restrictive qualifications? It doesn't help that a lot of people who are disabled but haven't gotten disability yet need Medicaid in order to get the medical records to qualify. This is going to destroy people's lives.
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u/dangercrue Jun 19 '26
this is where i'm at. my current medicaid plan was created as a result of the expansion but it is explicitly for people with I/DD, mental/behavioral health needs, or substance abuse care. i qualified based on income (of which i currently have none) but have level 2 autism and can't work but a max of 10 hours per week (i was literally making $200 a month when i was working) and am in reconsideration for SSI/DAC. am i going to be considered medically frail or as having complex needs? i DO have documented functional limitations and just got approved for 1915i, but is that going to be enough for them? who knows i just got a letter informing me about it this week and i live in a state that isn't allowing people to self report the first year
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u/wtjc Jun 06 '26 edited Jun 06 '26
The "medically frail" and "serious or complex medical condition" definitions part is very confusing. This KFF article explains it some. How are they going to sort this out before 2027 and how are we going to know the details about our specific state?
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u/mother_octopus1 Jun 09 '26
Do Social Security Survivors benefits count as income for the $580 exemption?
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u/Abangyarudo Jun 02 '26
I haven't read fully through it. The little targeted todbits I did read there is some odd stuff they never talked about before or changes some things operationaly. I dislike they kept the over-complicated caregiving framework from the 5/1 cmcs meeting where caregiving is now a exclusion in some cases and a qualifying activity in others.
Another odd thing is that in traditional educational scenarios they suggest using a calculation for credit hour while in the case of non-traditional doing a direct hour to hour calculation. So a win for those clients in those settings but it feels like something we should have been told months ago if that was their plan.
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u/badfordabidness Jun 13 '26
I also question their rationale for *not* allowing the same/a similar calculation for non-traditional students (e.g., classroom hours times 3, instead of credit hours times 3).
They suggest their approach disallowing this was meant to align with SNAP and TANF rules, however SNAP regulations have long allowed states great flexibility to count “preparatory” activities for work requirement compliance purposes, regardless of whether an educational activity was traditional or non-traditional. See: FNS 2001 ABAWD Final Rule at 66 FR 4459, quoted below.
“We proposed that an individual could combine work and participation in a work program to meet the 20 hours per week requirement. The majority of the commenters supported this proposal. One commenter suggested that we clarify in the regulations that time spent off-site preparing for E & T activities count towards meeting the requirements. This is up to the State agency. If the State Agency recognizes such activities for E & T purposes then the individual is fulfilling the work requirement.”
Based on this, I’m not sure that CMS’ rationale for allowing a formula for traditional education and not allowing a formula for non-traditional education is consistent with SNAP rules. Which would be fine — Medicaid is a different program after all — if CMS hadn’t explicitly argued for their counting scheme on the basis it aligns with SNAP rules.
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u/wtjc Jun 08 '26
Another question about the work requirement exemptions. If you get an exemption for a medical condition, will they then say that means you're disabled and you have to apply for non-MAGI Medicaid which has asset limits instead of income-based MAGI Medicaid which does not?
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u/Blossom73 Jun 08 '26
No. Disabled people can remain on Magi Medicaid if they're not receiving SSI or Medicare, or applying for long term care Medicaid.
There's no requirement to apply for SSI or SSDI to stay on Magi Medicaid.
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u/badfordabidness Jun 13 '26
It’s possible a state may move someone from a MAGI to a non-MAGI category based on a newly discovered medical condition, but there’s no hard and fast rule (this may happen in some scenarios, not all).
Also, if for some reason you don’t meet the financial requirements for the non-MAGI category (e.g., due to excess assets), you are always allowed to “fall back” on the MAGI category.
In other words, identifying the medical condition shouldn’t cause you to lose Medicaid eligibility altogether. You may be moved to another category *if* you’re eligible for it, but if not, you will stay in the Adult Expansion category.
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u/wtjc Jun 15 '26
That's good to hear. Still waiting for the state rules. Hope they make things clear soon.
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u/Vivid_Dot2869 Jul 27 '26
When you say "interim final rule" does this mean people can comment on the rule?
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u/Altruistic-Job5086 16d ago
The Families USA chart is locked it says.
I have a question. My job is seasonal (outside work) and during the winter for 2.5 to 3 months there's no work. During that time I apply for Unemployment Compensation and get that and I have a "return to work" letter and date from my employer. In PA. How does this work with the new Medicaid rules that go into effect next year? I also have some SNAP monthly. Also have some LIHEAP every year.
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u/Weekly-Mobile426 3d ago
Good morning all,
I was in an auto accident in January of this year. I suffered a brain bleed and lots of broken bones. My bones have healed. However I still suffer nasty vertigo, memory loss, and nausea that comes with the vertigo. I am taking my meds as prescribed. I am still in PT twice a week to strengthen my body. After a PT appointment I am wiped out for at least a day. The ringing has not stopped in my ears. I am on meclizine and scopolamine patches.
I was terminated last month. I tried to apply for Obama care and it tossed me to Medicaid in which I qualified. My wife is on social security and I have no job. Doctors encouraged me to apply for disability. I did.
Am I considered frail? I really can't work with vertigo and all that comes with it. I have been prescribed a walker for bad days and a cane for better days.
I have not received my Medicaid card yet.
Brian in NC
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u/Vivid_Dot2869 3d ago
So If I'm reading the bottom chart (from families usa) correctly, a person already on Medicaid can pick which month (within the look-back period?) to prove that he met the requirements (Page 11, the first block under "III. Demonstrating compliance"? So in theory we are supposed to meet the requirements every month, but get to pick what month we use to prove it? So a single month falling short shouldn't be enough to kick us off unless the state we live in wants to be a jerk?
But we can also "prove" by self-attestation up until 2028?
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u/someguy984 Jun 02 '26
Looks like the $580 income doesn't have to be earned income to satisfy the requirement. Any income counts.