June 1, 2026
Contact: Mary Clare Toomey, APG Vice President of Communications
Tel: (202)-322–9729
WASHINGTON — Members of the more than 300 of America’s Physician Groups care for millions of Medicaid beneficiaries, particularly under contracts and other arrangements with managed Medicaid plans. As a result, APG is gratified about multiple provisions of the Medicaid Community Engagement Requirement Interim Final Rule (CMS-2454-IFC) released today, but also concerned about other aspects of the rule.
APG is grateful, for example, that the Centers for Medicare & Medicaid Services (CMS) proposes to allow persons seeking to enroll in Medicaid to attest to the existence of their pregnancies or other factors warranting exclusions from the new work requirements, subject to submitting confirmatory documentation later. At the same time, APG has numerous concerns about aspects of the proposed rule that will put individuals, their physicians, and states in next to impossible situations in terms of determining compliance with the community engagement requirements. Examples include individuals with common chronic conditions, or with “serious and complex” medical conditions that may impair their ability to comply with the requirements.
The proposed rule says, for instance, that having asthma, hypertension, generalized pain, Type 1 or II diabetes, and/or headaches, would not “significantly impair an individual’s ability” to meet the community requirements, and that the acuity of a serious or complex condition may fluctuate such that it may no longer impair one’s ability to work. These statements suggest that individuals on Medicaid with chronic or serious conditions may be forced into a nearly endless cycle of doctors’ visits to determine how ill they really are and whether they can work; that states will similarly have to digest endless streams of such information about enrollees; and that states will also have substantial latitude to force enrollees off the program through subjective interpretations about their illnesses and their ability to work. It will be extremely difficult, if not impossible, to administer the community engagement requirements in a manner that will be workable, reasonable, and fair for individuals, states, and the health care system, and potentially millions of sick individuals could lose their Medicaid health coverage when they most need it.
APG will continue its analysis of the lengthy proposed rule, consult broadly with its members about their perspectives on it, and respond via comment letter to CMS in early August.
About America’s Physician Groups
APG’s more than 300 physician groups comprise of roughly 260,000 physicians and other clinicians providing care to nearly 90 million patients, including an estimated 1 in 4 Americans and 1 in 3 Medicare Advantage enrollees. APG’s motto, ‘Taking Responsibility for America’s Health,’ represents our members’ commitment to clinically integrated, coordinated, value-based health care in which physician groups are accountable for the costs and quality of patient care. Visit us at www.apg.org.
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