In a July 31 letter to the Centers for Medicare & Medicaid Services (CMS), America’s Essential Hospitals commented on the agency’s interim final rule implementing new community engagement requirements.
The association urged CMS to simplify enrollment and renewal processes, particularly for patients who qualify for medical frailty and short-term hardship exemptions.
Specifically, the association urged CMS to:
- Allow states to define medical frailty solely based on a condition or diagnosis
- Provide clear pathways to continuous coverage for patients who are newly diagnosed with conditions that qualify for medical frailty exemptions
- Not require qualified entities to assess community engagement requirement compliance for patients who qualify for Medicaid presumptive eligibility
- Ensure states have the maximum flexibility to implement optional hardship exclusions to preserve access to coverage for Medicaid-eligible patients
- Monitor and evaluate the effect of community engagement requirements on enrollment and eligibility and make this information publicly available in a timely manner
Contact Director of Policy Rob Nelb, MPH, at rnelb@essentialhospitals.org or 202.585.0127 with questions.
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