APIAHF Comment Letter Regarding CMS' Requirements for Community Engagement

Publish Date: July 31, 2026

Type: Testimony and Comments, Comment Letter

Topics: Health access, Health care, Medicaid, CMS, Comment letter

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Language: English

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APIAHF and its national AANHPI health partners submitted comments in opposition to the Department of Health and Human Services (HHS) Centers for Medicare & Medicaid Services’ (CMS) requirements for community engagement as stated by the Interim Final Rule (IFR) on the Medicaid program’s community engagement requirement for certain individuals.

APIAHF and its partners, the Association of Asian Pacific Community Health Organizations (AAPCHO), the National Asian Pacific Center on Aging (NAPCA), and the National Council of Asian Pacific Islander Physicians (NCAPIP) submitted comments urging CMS to revise or withdraw the IFR and accordingly take the following steps:

1. Rescind the medical frailty documentation requirements;

2. Restore self-attestation where appropriate;

3. Permit states to rely on existing eligibility and administrative data;

4. Extend implementation timelines;

5. Strengthen language access and civil rights protections; and

6. Preserve automatic exemptions for qualifying populations.

2026_07_31_CMS IFR Work Requirements Comment Letter.pdf

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