States Submit First Beneficiary Advisory Council Annual Reports Under CMS Access Rule
States submitted their first Medicaid Beneficiary Advisory Council (BAC) annual reports in July 2026, as required under the May 2024 CMS Access Rule (§ 431.12). The reports, now publicly available from multiple states including the District of Columbia, document each state's initial year of BAC implementation, covering varied time periods and ranging from four to over seventy pages. First-year activities focused heavily on establishing the councils — recruiting members, setting operating procedures, developing bylaws, and providing foundational Medicaid education to BAC members. State Health and Value Strategies has compiled these reports in a public tracker, revealing substantial variation in reporting approaches, meeting documentation, and stages of organizational maturity as states built on existing enrollee engagement structures or created entirely new advisory bodies.
These reports provide the first public view of how states are operationalizing the Access Rule's beneficiary engagement requirements, establishing benchmarks for what counts as reportable BAC activity and how states document enrollee input to Medicaid agencies.
Managed Care
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