Managed Care Plans Face January 2027 Deadline as CMS Issues Work Requirement Rule Projecting 15% Disenrollment

CMS's June 2026 interim final rule establishes Medicaid community engagement requirements effective January 2027, applying to non-pregnant adults 19-64 in expansion populations across 43 states and DC. The rule includes a stricter-than-expected medical frailty exemption requiring ADL impairment and prohibits states from delegating eligibility verification to MCOs, while CMS projects combined 15% disenrollment from noncompliance and procedural issues. MCOs must now prepare operational strategies to mitigate enrollment loss and support members in meeting requirements, even as they cannot directly perform eligibility verification.

Managed Care

This is outside commentary from Avalere, not part of Medicaid Monitor's independently scored news coverage.

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