Advocates Warn Administrative Burdens Will Lead Eligible People to Lose Health Care Coverage
Washington, D.C. — Today, the Centers for Medicare & Medicaid Services (CMS) released a major Interim Final Rule implementing key Medicaid eligibility and enrollment provisions enacted under the so-called One Big Beautiful Bill Act (OBBBA).
The rule establishes the federal framework for new Medicaid work requirements, eligibility checks, reporting obligations, exemption processes, and other administrative requirements that states must implement in the coming months and years.
While the full impact of the rule will depend on both the federal guidance and state implementation decisions, the National Health Law Program (NHeLP) warns that new administrative barriers could make it significantly harder for eligible people to enroll in or maintain the health care coverage they rely on.
“Work requirements and other new administrative barriers are bad policy. They do not make people healthier, help people find jobs, or improve access to care. Their primary effect is to make health coverage harder to get, harder to keep, and easier to lose,” said David Machledt, Director of Medicaid Delivery Systems at the National Health Law Program. “Even if they could be implemented with great care, these policies create new layers of paperwork, reporting obligations, and bureaucratic hurdles that prevent access to critical healthcare. NHeLP and our partners will work to ensure these requirements are implemented as fairly as possible and to mitigate the harm they cause, but the reality is that millions of people are now facing new barriers between themselves and the health care they need.”
NHeLP is currently reviewing the rule and assessing its implications for Medicaid enrollees, people with disabilities, families, providers, and state Medicaid agencies nationwide.
The rule will determine how difficult it is for people to obtain and keep Medicaid coverage, including what documentation they must provide, how disability and caregiving exemptions are evaluated, how eligibility reviews are conducted, how states communicate with enrollees, and when coverage can be terminated for failing to meet reporting requirements.
Implementation of these provisions will require significant burdensome operational changes by state Medicaid agencies and could harm millions of people who depend on Medicaid for access to preventive care, prescription medications, behavioral health services, long-term services and supports, and other essential health care.
California Implications
The rule will also have significant implications for California’s Medi-Cal program, which provides health care coverage to approximately 15 million Californians.
Federal implementation decisions will shape how California designs and administers new eligibility verification processes, reporting requirements, exemptions, and enrollee communications.
“The biggest concern for California is that people who are still eligible for Medi-Cal will lose their health care because of complicated paperwork requirements, reporting systems, and administrative red tape,” said Alicia Emanuel, Director of Eligibility & Enrollment at the National Health Law Program. “The details of this rule will determine whether Californians can realistically keep the coverage they rely on to see a doctor, manage chronic conditions, and stay healthy in their communities.”
NHeLP’s California advocates will continue working with state partners, policymakers, and community organizations to analyze the rule and help protect access to Medi-Cal coverage for Californians.
