In early 2025, the Commission initiated analytic work to identify considerations for implementing community engagement (CE) requirements in Medicaid. This work responded to state and federal efforts to pursue such requirements, initially through Section 1115 demonstrations and subsequently through legislation (an Act to Provide for Reconciliation Pursuant to Title II of H. Con. Res. 14 (2025 Budget Reconciliation Act), Public Law 119-21). The 2025 Budget Reconciliation Act established CE requirements and delegates to the Secretary the authority to set certain standards and procedures that the Centers for Medicare & Medicaid Services (CMS) addressed in the interim final rule with comment (IFC), issued on June 1, 2026.
This session summarized key IFC provisions, including individuals subject to CE, exceptions and exclusions from CE, state verification requirements, and beneficiary outreach requirements, as well as additional CMS resources. The Commission has indicated a strong interest in the CE policy and will monitor implementation activities. This session outlined the Commission’s framework for monitoring CE implementation.