The Medical Frailty Rule is Illegal and Irrational; the Consequences for Medicare are Profound
This article examines the medical frailty rule and it's impact on community health centers and other federal programs like Medicare.
Other Reports and Research
In addition to the Program’s signature policy briefs and data notes, the Geiger Gibson Program faculty and staff author peer-reviewed publications, reports and blogs for prestigious health policy outlets such as The Commonwealth Fund, Health Affairs, Kaiser Family Foundation, and The Milbank Quarterly. Additionally, the program’s legal research and impact analyses is presented in amicus scholars briefs designed to provide the courts with expert analyses of the implications of legal actions under review.
Search our Other Reports and Research Archive
This study from Kristine Kwon, Feygele Jacobs, and Leighton Ku describes trends and challenges in behavioral health care and social service delivery provisions using 2020 and 2024 Uniform Data System data and the 2023–2024 Commonwealth Fund CHC Survey data.
Public comment on the Interim Final Rule with Comment (IFR) implementing the H.R. 1 work and community engagement requirements, “Medicaid Program; Community Engagement Requirement for Certain Individuals” (CMS-2454-IFC) as filed July 2026.
Medical Frailty Rule Contravenes HR 1, Burdens The Health Care System, And Threatens Public Health
Writing in Health Affairs Forefront, the Geiger Gibson team and colleagues examine the Interim Final Rule (Medicaid Program; Community Engagement Requirement for Certain Individuals, CMS-2454-IFC) and its impact on health care access and health care providers.
H.R. 1 Funding Cuts Will Overshadow Gains from the New Rural Health Transformation Program
This 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.
The Trump Administration Comes for Title VI of the 1964 Civil Rights Act
In this Milbank Quarterly opinion piece, Sara Rosenbaum writes about recent changes to Title VI enforcement and the implications of this change on health systems.
Implementing Medicaid Work Reporting Requirements: Defining A ‘Serious Or Complex Medical Condition’
A new blog in Health Affairs Forefront looks closely at the “medically frail” exemption category in the statute, focusing on the subcategory “serious or complex medical condition.”
What’s In a Name? Challenges Facing Community Health Centers After HR 1
A new blog in Health Affairs Forefront explores the identify of community health centers and how health centers are adapting to address policy changes affecting their patients and financing. Authored by Sara Rosenbaum, Feygele Jacobs, and Marsha Regenstein.
Millions of Community Health Center Patients to Lose Coverage When Tax Credits Expire
A new Commonwealth Fund blog finds nearly 2 million community health center patients are likely to lose their coverage due to reduced ACA marketplace subsidies and rising premiums, with even greater losses likely in coming years.
Expiring ACA Premium Tax Credits Could Lead to Nearly 340,000 Jobs Lost Across the U.S. in 2026
A new policy brief examines the financial and economic impacts of the expiring ACA premium tax credits. Authored by Leighton Ku, Taylor Gorak, Kendal Orgera, Kristine Namhee Kwon, Maddie Krips, and Joseph Cordes.