CMCS Issues CIB Summarizing Community Engagement Statutory Requirements
In December, the Center for Medicaid and CHIP Services (CMCS) issued an informational bulletin (CIB) providing an overview of the Medicaid-related “community engagement” requirement mandated by HR. 1. While the CIB contains no new policy, it offers a clear summary of new state obligations related to implementing the requirements.
The document clarifies that “applicable individuals” (those who must demonstrate that they meet the community engagement requirements) are, “generally, those eligible to enroll or who are enrolled under the state plan in the adult group… or those who generally fit the description of [such] a person but who are eligible under or enrolled in a section 1115 demonstration that provides minimum essential coverage (MEC).” This means that “the community engagement requirements…do not apply in states that: a) have not adopted the adult group under the state plan; and b) do not have a section 1115 demonstration that offers MEC to individuals who are at least 19 and under 65 years of age, not pregnant, not entitled to or enrolled in Medicare Part A or B, and not otherwise eligible under the state’s Medicaid state plan.”
The CIB goes on to summarize the community engagement requirements, exclusions, and exceptions that are included in the statute but does not offer any further insight into how CMS intends to define them, including the exemptions for family caregivers and individuals who are “medically frail.”
The document notes that “States must require Medicaid beneficiaries who are subject to community engagement to demonstrate compliance for one or more months in between renewals,” and indicates that “CMS interprets this to mean that a beneficiary is considered to have successfully met the requirements if during any part of the eligibility period the beneficiary demonstrated community engagement for the number of months the state specified.” That is, “the state may not dictate the specific months during which an applicable individual must demonstrate community engagement,” nor may it require that they be consecutive.
The guidance emphasizes that states must establish processes that include first attempting to use data sources already available to the state, to determine whether an individual does or does not meet the CR requirement or is exempt. CMS provides a non-exhaustive, general list of reliable data sources: “payroll data, Medicaid provider payments, or encounter data, and data sources about higher education enrollment, job training participation, or community service.” CMS indicates that “the state may not request additional information or documentation unless it is unable to establish that the individual met community engagement requirements (or was not required to do so) using reliable information available to it.”
FMI: Read the CIB at https://www.medicaid.gov/federal-policy-guidance/downloads/cib12082025.pdf.
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