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Considerations for Implementing Community Engagement Requirements: Findings from Stakeholder Interviews

States will soon be required to make Medicaid eligibility for certain applicants and existing beneficiaries contingent on their participation in qualifying community engagement activities in accordance with Public Law 119-21, an Act to Provide for Reconciliation Pursuant to Title II of H. Con. Res. 14 (2025 Budget Reconciliation Act). This session revisits the details of the new community engagement requirement and highlights key implementation considerations for states and the Centers for Medicare & Medicaid Services (CMS) based on stakeholder interviews. The considerations generally focus on state processes for determining compliance and exceptions, including key questions related to Medicaid IT systems and data availability. States and other stakeholders also highlighted areas where states would benefit from timely federal guidance, technical assistance, and other support. The Commission is interested in plans to monitor community engagement requirement implementation and will have further discussion of that topic at MACPAC’s January public meeting.