In a letter to Centers for Medicare & Medicaid Services (CMS) Administrator Dr. Mehmet Oz, the Medicaid and CHIP Payment and Access Commission commented on CMS’s interim final rule with comment period (IFC) on the community engagement (CE) requirement for certain individuals in Medicaid.
The Commission’s comments in the letter focus on enrollment and eligibility and draw primarily from the Commission’s research and analysis of work and CE requirements through Section 1115 demonstrations, as well as MACPAC’s more recent work since enactment of this new requirement. The Commission has recommended that CMS develop a transparent monitoring and evaluation plan for assessing CE implementation.
The Commission supports the policy included in the IFC that requires state submission of monitoring data that will provide information regarding the status and success of CE implementation. However, the Commission expressed concerns that the short implementation timeline, complexity of policies, and scope of needed systems changes will impede states’ ability to implement CE requirements in a timely way that ensures eligible individuals obtain and maintain coverage. The Commission is also concerned that certain IFC policies will limit CMS’s and states’ abilities to ensure eligible individuals obtain and maintain Medicaid coverage, especially those who are medically frail. The Commission urged CMS to adopt MACPAC’s recommendation to publish monitoring data in a timely manner and establish a requirement for evaluating CE requirements.