Federal Policy
Health Care Coalition Seeks HHS Clarification on SUD Community Engagement Exemptions
ACAP and a coalition of health care organizations submitted a letter to HHS on February 7, 2026, requesting clarification on how Medicaid managed care plans should verify and document substance use disorder (SUD) treatment exemptions from community engagement requirements. The letter addresses operational challenges MCOs face in implementing exemption processes without clear federal guidance on documentation standards, member privacy protections, and coordination with SUD providers. The coalition seeks guidance on verification procedures to ensure eligible beneficiaries receive exemptions while maintaining compliance with federal requirements.
Why it mattersMCOs implementing community engagement requirements need clear federal standards for verifying SUD exemptions to avoid inappropriate coverage terminations and ensure compliant exemption processes.