The AAMC raised significant concern with an interim final rule (PDF) implementing the statutory requirement in the One Big Beautiful Bill Act (OBBBA, P.L. 119-21, PDF) that certain adult Medicaid enrollees meet community engagement (i.e., work) requirements. Under the rule, certain adults must complete 80 hours of qualifying activities per month, such as employment, enrollment in an educational program, or community service, to maintain their coverage [refer to Washington Highlights, June 5].
In its July 29 comments to the Centers for Medicare & Medicaid Services (CMS), the AAMC expressed concern that “certain provisions of the rule extend beyond the statutory language," and would "jeopardize coverage for vulnerable individuals who Congress intended to protect, while also significantly increasing administrative burden on physicians and other health care professionals, patients, and state Medicaid programs.” The letter urged the agency to revise the definition of “medical frailty” by removing the requirement that individuals establish that their condition impairs their ability to meet community engagement requirements, maximize the use of ex-parte verification processes, consult with physicians and other stakeholders when developing processes to determine medical frailty, and extend the self-attestation period, among other recommendations.