RCPA Submits Comments on CMS H.R. 1 Medicaid Interim Final Rule of Work Requirements
Author
Jim Sharp
Date
July 30, 2026
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The Rehabilitation & Community Providers Association of Pennsylvania (RCPA), on behalf of our members and stakeholders, has submitted comments on the Centers for Medicare & Medicaid Services (CMS) Interim Final Rule with Comment Period (IFC) addressing Medicaid community engagement requirements in 91 Federal Register (“FR”) 33348. This IFC interprets and implements the community engagement requirement in Medicaid under Section 1902(xx) of the Social Security Act. States are required to implement the new requirement no later than January 1, 2027.
RCPA’s comments reflect the position of our membership and our partnership with the National Council for Mental Wellbeing, whose visions, missions, and, most importantly, individuals served will be deeply impacted by the implementation of this and several of the proposed changes as a result of the H.R. 1 bill.
Federal Medicaid work requirements are a new eligibility condition for adults in Medicaid expansion and certain waiver programs, requiring engagement in work, education, or community service. While exemptions exist for vulnerable populations, states must implement systems to track compliance, and the policy is expected to have significant fiscal and coverage impacts.
If you have questions, please contact RCPA COO Jim Sharp.



