Comments on Medicaid Community Engagement Requirements Interim Final Rule

On July 31, the MLTSS Association submitted comments on CMS’s interim final rule on the implementation of Medicaid Community Engagement (CE) requirements. Overall, our comments focus on the areas where additional clarity would most improve implementation, particularly the accurate identification of individuals who qualify for the medically frail and caregiver exemptions. Our recommendations are grounded in a shared goal of implementing the statutory requirement in a way that is feasible for states, workable for plans and providers, and, above all, protective of the individuals for whom Medicaid serves as a lifeline, including older adults and individuals with disabilities. 

The MLTSS Association also wrote a letter to State Medicaid Directors outlining recommendations that would allow states to meet their CE obligations while minimizing avoidable coverage loss among the medically frail, disabled, and caregiver populations our members serve. Additionally, our recommendations promote consistency across states, ease administrative burden for plans that operate in multiple markets, and help ensure comparable protections for members regardless of where they live.

Read our full CMS comments here

Read our letter to State Medicaid Directors here