Interim Final Rule Implementing Medicaid Community Engagement Requirements
On June 1, CMS issued its long-awaited Interim Final Rule (IFR) implementing the Medicaid community engagement provision of H.R. 1. The IFR, Medicaid Program; Community Engagement Requirement for Certain Individuals (CMS-2454-IFC), is effective July 31, 2026, a date coinciding with the end of the public comment period.
Writing in Health Affairs Forefront, the Geiger Gibson team and colleagues examine the IFR and its impact on health care access and health care providers. They point out that the rule diverges widely from state expectations based on prior informal guidance over months of discussion. Furthermore, the IFR’s approach to “medical frailty” runs counter to Medicaid’s purpose and ignores the clear language of the statute. In effect, it strips the law of critical health care access and coverage safeguards, seriously endangering the health of low-income working-age adults, and with serious implications for community health providers.
The report, CMS’s Medical Frailty Rule Contravenes H.R. 1, Imperils Millions, Creates Untenable Burdens on the Health Care System, and Is a Threat to Public Health is authored by Sara Rosenbaum, Feygele Jacobs, Alison Barkoff, Allyson Crays, Caitlin Murphy Lindsay Farrell, Jane Tavares and Marc Cohen (UMass – Boston’s The LTSS Center.)
State-Level Impact Analysis of HR 1 Funding Cuts
Leighton Ku, Director of GW’s Center for Policy is the lead author of a new report released by the Commonwealth Fund, H.R. 1 Funding Cuts Will Overshadow Gains from the New Rural Health Transformation Program.
The report summarizes state-specific economic and employment effects of OBBBA cuts to Medicaid, the ACA Marketplace, and SNAP as well as of the Rural Health Transformation Program (RHTP) and the expiration of ACA enhanced premium tax credits. Overall, federal funding for health and nutrition programs will shrink by more than $1 trillion over a decade. These losses will have severe economic repercussions across the nation.
While the OBBBA adds $50 billion for the new Rural Health Transformation Program (RHTP), the modest economic gains related to RHTF will be overshadowed by losses from budgetary cutbacks. About 229,000 jobs will be lost nationally due to the health cutbacks in 2026 alone.
By 2029, Medicaid and ACA funding reductions will shrink state economic activity by $197 billion and eliminate 1.65 million jobs nationwide, about half of which will be in health care. State and local tax revenues will be more than $14 billion lower in 2029.
Leighton Ku, Kendal Orgera, Kristine Namhee Kwon, Taylor Gorak, Maddie Krips, and Joseph J. Cordes authored the report.