What the June 1 CMS Medicaid rule means for health centers and why your voice matters

The June 1 CMS interim final rule on Medicaid work requirements included in H.R.1 is now out and the clarifications around community engagement requirements are drawing concern from community health advocates.

The rule requires 80 hours per month of qualifying activities - including work, education and community service - in order to be eligible to receive Medicaid, with states required to implement the rule by January 1, 2027.

Some populations are categorically exempt, including:

• Pregnant and postpartum individuals
• Veterans with a total disability rating
• Caregivers of young children
• Former foster care youth
• American Indians and Alaska Natives.

For many others - including those with serious medical conditions - exemption must be proven on an individual basis.

Consider a patient managing HIV or cancer. Under the new rule, their diagnosis alone is not enough to exempt them. Each individual must separately demonstrate that their specific condition prevents them from meeting the 80-hour requirement, even when their condition is thoroughly documented in their medical records.

Many Medicaid patients already meet the 80-hour requirement, but proving that is burdensome for patients, providers and states.

With this interim final rule, it just became even more burdensome.

There is a slight temporary reprieve: states can accept self-declaration of medical frailty through 2027. But starting in 2028, self-attestation is allowed only once per enrollment period, after which documentation is required at every renewal.

Navigating recurring documentation requirements is genuinely hard, especially for people already managing serious illness, unstable housing or limited access to technology. And when patients lose coverage and delay care, health centers absorb the cost.

Health centers know their patients. They see firsthand how hard it is for people managing chronic illness, unstable housing, or limited access to technology to navigate complex administrative systems - and how quickly a missed renewal can mean delayed or foregone care.

That expertise is exactly what's needed in the public comment period, which is open until July 31, 2026.

CMS needs to hear from the providers who will feel the real-world impact of this rule, and from the advocates who understand what's at stake for the millions of patients community health centers serve.

Submit comments here before July 31, 2026: regulations.gov/docket/CMS-2026-2047

Related: How CHCs can build a sustainable path in the wake of H.R.1 in 2026

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