DHS Releases Preliminary HR 1 Plan Documentation for Review and Feedback

RCPA Presents HR 1 Medicaid Summit

RCPA would like to thank our members and stakeholders for joining the RCPA HR 1 Medicaid Summit this morning with our Federal and State partners. The Summit provided an excellent opportunity to hear about the Federal and State landscape of HR 1 implementation and act as a call for collaboration in ensuring vulnerable Pennsylvanians have ongoing access to care. RCPA will be providing a follow up to the webinar as well as an RCPA HR 1 Medicaid Resource Guide in the coming weeks.

This morning, DHS released the following set of communications and documents related to the State’s HR 1 implementation. The release of these preliminary guidances provides the backdrop for members to review and provide feedback. This activity supports the collaborative process of a successful implementation and we hope stakeholders take advantage of this opportunity. Organizations and individuals can submit their feedback via this email or through RCPA by Friday, May 29. 

Documents List

1. Pennsylvania’s Proposed Medical Frailty Process
2. DRAFT PA Medical Frailty Codes
3. CER Overview Slides
4. Visuals of COMPASS New Application
5. Visuals of COMPASS Renewal
6. CER Initial Outreach Letter – initial outreach letter informing individuals currently in the Medicaid Expansion Population, and those joining the Medicaid Expansion population prior to 1/1/27, of upcoming CER requirements and key information
7. CER Outreach Letter Periodic – recurring outreach will be periodic as determined by CMS
8. CER Non-compliance Notice Application – CER non-compliance notice informing new applicants of the specific due date (35 days from the mail date) by which they must demonstrate CER compliance or exclusion
9. CER Non-compliance Notice Renewal – if CER exemption/compliance cannot be determined during ex parte, notice informing individuals of the specific due date (35 days from the mail date) by which they must demonstrate CER compliance or exclusion
10. CER Self-Assessment – CER self-assessment form allowing individuals to self-attest to CER activities and exemptions when that information is not provided on the application; mailed with the CER Non-Compliance Notice

Regarding the medical frailty overview and draft code list – in 2025, federal changes to the Medicaid program created community engagement requirements for certain individuals in the adult Medicaid expansion population beginning in January 2027. The law exempts certain individuals from these requirements, including an individual who is “medically frail or otherwise has special medical needs.”

The attached code list is a preliminary technical reference intended to support administrative review of existing records. It is not the only pathway for identifying medical frailty. DHS also expects to use additional available information, and some individuals may need to provide information when medical frailty cannot be identified through administrative records.

Please note that the documents are drafts and remain subject to change. The code list has not been approved by CMS and may be updated as implementation planning continues, clinical and operational review advances, and final CMS guidance is issued.

If you have questions and or would like your organizations feedback for included in the RCPA comments, please contact RCPA COO Jim Sharp or Policy Specialist Emma Sharp.