The Senate’s entire Democratic caucus, made up of 45 Democrats and two aligned independents, sent a letter to CMS Administrator Mehmet Oz, MD, Aug. 4, calling upon the agency to withdraw its June interim final rule regarding Medicaid work requirements.
The community engagement rules are supposed to go into effect for the Medicaid expansion population in 2027, with some states already getting a head start. As established by HR 1, most adults in this group must work, engage in community service or attend school for at least 80 hours per month.
“This rule transforms Medicaid from a healthcare program into a bureaucratic maze that will fail eligible Americans,” the letter read. “It will strip coverage not because people are not already working or refuse to work, but because they cannot navigate a complex web of forms, passwords and deadlines.”
Among the senators’ critiques: the scope of “medical frailty” exemptions. They said the interim final rule tacked on a requirement for conditions to “significantly impair” an individual’s ability to comply, whereas HR 1 specifies that some types of conditions alone warrant an exemption. The June rule “establishes a much narrower pathway to the exemption than HR 1 permits,” the letter read.
Come 2028, states will need to be stricter with which documentation they accept to confirm medical frailty exemptions, as well.
“The verification requirements in 2027 compared with 2028 function as a bait-and-switch,” the letter read. “To the extent that implementation looks potentially manageable in the first year, then procedural barriers and coverage losses spike when the documentation default kicks in.”
Senators also expressed concerns regarding how the work rules will interplay with six-month eligibility checks.
“By combining the six-month eligibility renewal requirement with ongoing work-reporting checks, this rule ensures that families are never not in the process of signing up for healthcare, effectively setting a structural trap,” the letter read.
The interim final rule said one-time costs to upgrade eligibility systems would reach $15 million per state, or $660 million for the 44 states with expanded Medicaid or related Section 1115 waivers. However, as outlined in HR 1, the federal government only planned to appropriate $200 million to the undertaking in fiscal 2026.
The letter comes shortly after a request from 25 states, plus Washington, D.C., to block parts of the rule was denied.
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