January 14, 2026
Tracking Medicaid鈥檚 Growth: FFY 2025 Spending and T-MSIS Data Provide Insights on Managed Care Spending
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Webinar Replay – 2027 ACA Considerations: Proposed NBPP and Other Key Changes and Trends
This webinar was held on February 4, 2026 at 12pm ET.
Upon the release of the CMS final 2027 Notice of Benefit and Payment Parameters and the accompanying Letter to Issuers in January, health plans and state policymakers will face critical decisions that shape the next phase of the individual and small group markets.
Experts from 红领巾瓜报 and Wakely discussed what the proposed rule means in practice and how stakeholders can begin preparing now. This webinar provided a clear overview of the final 2027 NBPP** and Letter to Issuers, highlighted the most significant policy changes and clarifications, and explored the operational and strategic implications for states. Speakers focused on how the final policies may influence market stability, affordability, program administration, and longer-term planning for 2027 and beyond. 听听
** We expect that the NBPP will have been released before the webinar takes place, but if the NBPP is not yet released we will cover likely scenarios based on our best available information.
Learning Objectives:
鈥nderstanding the proposed 2027 NBPP and Letter to Issuers
鈥wareness of key implications for states and issuers
鈥iscussion of key planning considerations for 2027
Executive Branch Actions Target Drug Affordability in New Pricing Models
The federal drug pricing landscape continues to undergo significant transformation as executive branch agencies advance an ambitious suite of regulatory and model testing initiatives intended to lower the costs associated with the Medicare and Medicaid programs. In response to ongoing concerns about rising out-of-pocket costs, increasing pressure to align US prices with those paid internationally, and the continued implementation of the Inflation Reduction Act (IRA), federal agencies are reshaping how prescription drugs are priced, reimbursed, and negotiated in federally financed programs.
The current policy environment reflects a growing emphasis on benchmarking drug prices to those in peer nations, referred to as 鈥渕ost favored nation鈥� (MFN) benchmarks, and accelerating actions that require or encourage manufacturers to offer lower net prices. 红领巾瓜报 (红领巾瓜报), is tracking these developments in the public payer space, replicating Centers for Medicare & Medicaid Services (CMS) payment methodologies, and modeling alternative policies to assist life science companies, payers, and other stakeholders.
In this article, we review the administration鈥檚 recent efforts to reduce Medicare and Medicaid spending on drugs and biologics, including confidential manufacturer negotiations and three new models that together could reshape pricing dynamics across federal programs.
Executive Branch Negotiations Seek to Drive Access to MFN Discounts
In 2025, the administration issued an directing federal agencies to pursue strategies to establish MFN pricing, linking US prices for certain drugs to the lowest (or second lowest) adjusted net prices among a targeted set of peer countries. Following the order, federal officials sent to 17 major pharmaceutical and biotechnology manufacturers, urging them to negotiate agreements that would voluntarily align prices with MFN-based benchmarks.
To date, 14 manufacturers have signed , though full details remain confidential. These agreements are understood to accomplish the following:
- Provide听state听Medicaid听programs with听access to听MFNbased听discounts听
- Require that new drugs be launched in the United听States听at听MFNaligned听prices听
- Offer certain drugs at discounted听directtoconsumer听prices through a forthcoming 鈥淭rumpRx鈥� program, expected to launch later this year听
Reports suggest that manufacturers entering these MFN-related arrangements may receive exemptions from several federal actions, including the Center for Medicare and Medicaid Innovation (Innovation Center) demonstration models described below and certain tariff-related policies.
MFNLinked Models Designed to Lower Drug Costs Across Medicare and Medicaid
Along with the negotiation efforts, the CMS Innovation Center has proposed three models that would test MFNbased pricing through structured rebate mechanisms. Each model targets different segments of the market while testing how international benchmarks could be integrated into federal drug payment policy.
New Models Test Alternatives to Inflation Rebates
Announced in December 2025, the and the are designed to test alternative approaches to the Inflation Reduction Act鈥檚 (IRA) policies. CMS plans to test the models鈥� potential for market driven price reductions if manufacturers choose to lower list prices instead of paying MFN-based rebates.
Key features of the GLOBE Model are as follows:
- Applies听to听25 percent of听Medicare听fee-for-service听(FFS)听beneficiaries听using certain听Part B drugs听
- Beginning in October 2026,听becomes听mandatory听for select drugs and targets听highspending,听physicianadministered听Part B categories, excluding products already subject to IRA听negotiations, generics, biosimilars, and certain听lowspend听products听
- No changes to听physician and hospital听reimbursement,听although beneficiaries听expected to听see reduced cost sharing听
The GUARD Model will similarly test whether applying MFN-based rebates to Medicare Part D drugs will lower Medicare costs. Key aspects of this model include:
- Fiveyear听model听that would start听January 1, 2027听
- Target听therapeutic categories with more than $69 million in annual Part D spending听
- No impact on听plan bids and beneficiary cost sharing听
These models rely on pricing data from 19 countries. Manufacturers that voluntarily submit net price information would trigger quarterly benchmark updates; otherwise, CMS will use a fixed list price based benchmark for the entire pilot period.
CMS is seeking on whether additional categories, for example cell and gene therapies, should be excluded from GLOBE. GUARD is also open for through February 23, 2026.
GENErating cost Reductions fOr US Medicaid (GENEROUS) Model
The , expected to begin in 2026, creates a voluntary pathway for state Medicaid programs and manufacturers to enter supplemental rebate agreements tied to MFNaligned prices. MFN pricing under this model is based on the second lowest net price in G7 countries plus Denmark and Switzerland. GENEROUS is also expected to align with pricing commitments negotiated through the administration鈥檚 manufacturer agreements.
Key Considerations and Potential Impacts
The combined effect of federal negotiations and Innovation Center models could be substantial, though outcomes will depend on manufacturer participation, benchmark stability, and operational feasibility. Key considerations include:
- State听Medicaid savings, especially听the extent to which听MFN鈥憀inked rebates exceed existing supplemental rebates听
- Reduced Medicare beneficiary cost sharing for Part B included in GLOBE听
- Shifts in manufacturer pricing strategies, including potential changes to US launch prices听
- Interactions with the IRA, particularly Part D redesign and Part B inflation penalties听
Connect with Us
红领巾瓜报 experts continue to track the federal drug pricing landscape closely as comments, operational details, and implementation timelines evolve across these initiatives. Our team replicates CMS payment methodologies and models alternative policies using the most current Medicare FFS and Medicare Advantage (100%) claims data.
For more information听and听questions about the policies described听in this article, please contact听our experts below.
CMS Announces Rural Health Transformation Program Awardees
On December 29, 2025, the Centers for Medicare & Medicaid Services (CMS) the state awards for the Rural Health Transformation Program (RHTP), a $50 billion federal initiative intended to stabilize rural health systems and support transformation. CMS stated that $10 billion will be available each year from 2026 to 2030, and that first-year (2026) state awards average $200 million, with totals ranging from $147 million to $281 million.
This announcement marks a pivot from planning to execution. In the coming months, states will move rapidly to finalize governance structures, confirm partners, and translate proposed initiatives into operational workplans and measurable outcomes.
Although CMS announced the overall awards for the first budget year, some states have signaled they continue to work with CMS on initiative-specific budgets and planning. In this article, 红领巾瓜报 (红领巾瓜报) reviews key themes and early trends based on the application initiatives and what is known about the budgets.
What the Awards Suggest About State Priorities
Although each state鈥檚 awarded approach reflects local realities, early patterns across awardees鈥� project abstracts suggest several recurring priorities that may shape implementation activity in 2026.
1) Building the Data, Analytics, and Interoperability Backbone
A number of awardees prioritized shared infrastructure for interoperability, analytics, performance monitoring, and operational backbone capabilities. Examples include:
- Arizona described plans to secure vendors to build secure data pipelines, dashboards, and fiscal tracking tools that meet federal audit standards to support rural transformation.
- New Mexico proposed a Rural Health Data Hub to build a statewide health analytics platform that integrates siloed data sources and expands access to timely, actionable information for providers.
- Alaska described technology-focused investments to strengthen cybersecurity, facilitate data sharing and interoperability, and expand digital tools (including consumer-facing tools and remote modalities).
2) Strengthening Maternal Health and Perinatal Care
Many awardees emphasized stabilizing rural maternity access and strengthening perinatal supports through strategies, such as:
- Alabama proposed a Maternal and Fetal Health initiative featuring digital obstetric regionalization and telerobotic ultrasound to extend specialty access in rural settings.
- Kentucky prioritized maternal and infant health by addressing maternity care deserts, including telehealth-enabled community-based maternal/infant support teams and expanded perinatal care access.
- Ohio proposed legislative reforms to allow low-risk birthing centers in rural hospitals as part of its broader strategy to address maternity care deserts and improve rural access to care.
Why it matters: Rural maternity deserts and workforce constraints remain critical drivers of avoidable complications and adverse outcomes. Approaches piloted in rural settings may inform broader statewide maternity care strategies.
3) Modernizing Emergency Medical Services and Mobile Care
Several awardees included investments intended to strengthen emergency response and build more reliable rural stabilization capacity.
- Alabama proposed statewide emergency medical services (EMS) initiatives, including trauma and stroke routing/diversion improvements and an EMS treat-in-place model for low-acuity patients.
- Wyoming emphasized access to 鈥渢he basics,鈥� including improvements in the ability of hospitals to effectively treat emergencies and ambulance response, alongside incentives for small ambulance services to consolidate around more sustainable regional funding bases.
Why it matters: EMS and mobile response models can function as connective tissue in rural systems with limited traditional access points.
Why it matters: Data-sharing infrastructure can enable multi-provider coordination, performance tracking, and the operational foundations needed for sustainable transformation.
4) Integrating Behavioral Health and Community-Based Supports
Awards also reflected ongoing efforts to expand behavioral health access and improve integration with physical health and community supports. For example:
- Alabama proposed to improve behavioral health access by converting Community Mental Health Centers into Certified Community Behavioral Health Clinics (CCBHCs).
- Arizona proposed to invest in behavioral health and substance use disorder treatment expansion as part of its Priority Health Initiatives portfolio.
- Wyoming included statewide telepsychiatry and crisis intervention services as part of its health outcomes priorities.
Why it matters: Behavioral health capacity constraints are frequently more acute in rural areas, and integration strategies often require both reliable workforce and technology supports.
What to Watch Next
With awards announced, attention will quickly turn to implementation. Stakeholders should have processes to track the following:
- State governance decisions (including lead agencies, subawards, and regional structures) and funding opportunities
- State partner selection processes (through requests for proposals, vendor onboarding, or other contracting pathways)
- Performance measurement and reporting expectations (including metrics and evaluation approaches)
- Sequencing of the initiatives and where near-term operational activity is most likely to concentrate
CMS also signaled near-term oversight and engagement mechanisms, state-assigned CMS project officers, kickoff meetings, ongoing technical assistance, and regular progress updates, along with a planned annual CMS Rural Health Summit.
Tracking State RHTP Implementation
The 红领巾瓜报IS team developed a resource to capture available information about state RHTP activities, applications, and initiatives and provide a road map for identifying state-specific proposals, requested funding, governance structures, and other key aspects of state RHTP initiatives.
Following CMS鈥檚 award announcement, 红领巾瓜报IS is updating this Rural Health Transformation Program (RHTP) Tracker to incorporate award-specific details as they become publicly available. The resource includes information about FY26 awards by state and initiatives, links to CMS materials and state-posted implementation documentation, and a consolidated view of emerging themes and trends as implementation accelerates in 2026.
Looking Ahead
The award announcement is the beginning of implementation. As states operationalize initiatives in early 2026, organizations that align early to awarded priorities and implementation timelines will be best positioned to support rural-first efforts that deliver measurable and lasting results.
For questions about the RHTP opportunities for your organization and the solutions 红领巾瓜报 can tailor to meet the needs of your state, contact Kathleen Nolan and Andrea Maresca.
Webinar Replay – Meeting the Healthcare Needs of Unhoused People Part 1: Service and Care Responses
This webinar was held on January 27, 2026 at 12pm ET.
Thanks for joining us for the first of two webinars exploring how current events are impacting people experiencing homelessness and their access to care. This webinar highlighted the model of care for healthcare for the homeless clinics and medical respite care providers and how these services interact with broader systems of care. Additionally, we explored how the current environment is impacting delivery and financing of care for some of our most vulnerable neighbors.
Learning Objectives:
- Define the model of care for healthcare for the homeless and medical respite care
- Identify two ways that current events are impacting the delivery and financing of care for people experiencing homelessness
- Identify two strategies for supporting service providers working to support the healthcare needs of people experiencing homelessness.
Featured Speakers:
Julia Dobbins, MSW, Director of Medical Respite National Health Care for the Homeless Council
Lawanda Williams, MSW, MPH, Chief Behavioral Health Officer Health Care for the Homeless
Kim Despres, DHA, RN, CEO Circle the City
Catherine Crosland, MD, Medical Director of Emergency Response Sites Unity Health Care
Don’t miss out on Meeting the Healthcare Needs of Unhoused People Part 2: Service and Care Responses on February 3.
Webinar Replay – Meeting the Healthcare Needs of Unhoused People Part 2: State Policy Responses
This webinar was held on February 3, 2026 at 12pm ET.
Recent federal policy changes, such as the 2025 Budget Reconciliation Act (OBBBA), bring significant challenges to retaining the Medicaid coverage gains and added 1115 waiver services that have been so successful in the last decade. States will be under tremendous pressure to meet new requirements鈥攂ut they also have options to reduce the negative impact on vulnerable populations and the healthcare providers that serve them. This webinar to discussed state-level policy options, shared resources, and considered how to move forward in the current environment.
Learning Objectives:
- Identify three provisions in the 2025 budget reconciliation legislation that have a strong impact on unhoused people.
- Identify two policy actions that lawmakers in all states should take to reduce the loss of Medicaid coverage for people experiencing homelessness.
- Identify three policy actions that lawmakers in Medicaid expansion states can take to reduce the burden of work requirements on unhoused people.
Featured Experts:
Barbara DiPietro, PhD, Senior Director of Policy National Health Care for the Homeless Council
Rhonda Hauff, CEO Yakima Neighborhood Health Services Yakima, WA
Kevin Lindamood, President and CEO Health Care for the Homeless, Baltimore, MD
Don’t miss out on Meeting the Healthcare Needs of Unhoused People Part 1: Service and Care Responses on January 27.
2025 Year-End Wrap-Up: ACA Subsidies and What to Expect in 2026
As 2025 draws to a close, Congress finds itself at a crossroads on several critical health policy issues, with the fate of the Affordable Care Act (ACA) subsidies front and center. The year has been marked by intense negotiations and a flurry of proposals, many of which remain unresolved as lawmakers look ahead to a pivotal January 30 deadline for appropriations spending bills. In this article, policy experts from 红领巾瓜报 (红领巾瓜报)鈥攊ncluding Leavitt Partners, an 红领巾瓜报 company鈥攑rovide a comprehensive wrap-up of Congress鈥� work on ACA subsidies, executive agency actions, and what stakeholders should anticipate in early 2026.
ACA Subsidies: A Year of Uncertainty and Political Maneuvering
The expiration of enhanced ACA subsidies at the end of 2025 has been a focal point for congressional debate. Despite numerous bipartisan groups and a multitude of proposals circulating, consensus has proven elusive. The Senate voted on an ACA-related measure December 11, 2025, but neither the Democrats鈥� proposal for a three-year extension nor the Republican alternative to replace subsidies with health savings accounts advanced and revise certain other Medicaid policies.
The situation in the House has been equally complex. House GOP leaders unveiled a healthcare package designed to lower costs, expand association health plans, and increase transparency for pharmacy benefit managers. The package would not extend the expiring enhanced ACA subsidies, and even if the House bill passes, the Senate is unlikely to consider it. In addition, on December 17, House Democrats secured enough support to force a vote on a bill that would provide a three-year extension of enhanced subsidies, although House rules preclude scheduling a vote on the bill until January.
The听prevailing sentiment among policy experts is that no substantial action will be taken before year鈥檚 end.听
The White House briefly floated a two-year extension of the enhanced subsidies, but walked back the proposal, signaling fluidity in the policy discussions within the administration and among congressional Republicans. The absence of consensus on both policy and political ramifications has left the ACA subsidy issue in limbo.
Looking Ahead: January鈥檚 Appropriations Deadline and ACA Options
December 15, 2025, marked the last day for consumers to enroll in ACA coverage policies that take effect January 1, 2026, meaning that for many health insurance purchasers, choices for 2026 are already set. Policymakers are now focused on another deadline for potential ACA subsidy action鈥擩anuary 30, 2026, when temporary funding for the current federal fiscal year expires. It is possible that a solution could be attached to the spending package, potentially affecting 2026 premiums, although operational challenges abound. The most feasible option at this stage would be a premium rebate, which would avoid reopening enrollment but require complex rate adjustments. Any substantive changes to the subsidy structure would demand significant actuarial analysis and could disrupt both health plans and state activities.
Congressional Dynamics: Appropriations, Extenders, and Policy Riders
The appropriations process is center stage as Congress approaches the January 30, 2026, deadline. Lawmakers are seeking to continue passing 鈥渕inibus鈥� packages鈥攕mall groups of appropriations bills鈥攖o avoid another government shutdown. Most Medicare and Medicaid policy priorities, including must-pass extenders like telehealth flexibilities and the hospital at home program, are dependent on appropriations vehicles to advance. If Congress resorts to a stopgap continuing resolution, only the most essential extenders are likely to be included, with broader policy riders at risk of being sidelined.
Policy Outlook
Pharmacy benefit manager (PBM) reform stands out as a top bipartisan priority, with both House and Senate members eager to advance transparency and de-linking measures. Other lingering issues from the December 2024 healthcare package include Medicaid spread pricing prohibitions, streamlined enrollment for out-of-state providers, and targeted benefits for military service members. In Medicare, multi-cancer early detection screening and digital health policies may resurface, though larger reforms like Medicare physician fee schedule changes are likely to be deferred until later in 2026.
Agency Developments: CMS Innovation and Regulatory Changes
Beyond Congress, the Centers for Medicare & Medicaid Services (CMS) has been active, rolling out new models and rules that will shape the landscape in 2026 and beyond. Highlights include the 2027 Medicare Advantage Policy and Technical Changes Proposed Rule. Although it introduces no major policy shifts, the proposed rule addresses quality measurement, special needs plans, the Health Equity Index, and administrative burden reduction. It also codifies changes from the Inflation Reduction Act, such as cost-sharing and out-of-pocket limit reforms. The new ACCESS model (Advancing Chronic Care with Effective, Scalable Solutions) is intended to incentivize tech-enabled care for chronic conditions, with the model beginning July 2026.
CMS also released updates to the outpatient, home health, and durable medical equipment rules, with a continued focus on site neutrality (aligning payments across settings) and removing barriers to beneficiary choice. The agency is placing ongoing emphasis on data collection, price transparency, and updated payment methodologies to reflect modern practice and technology. The (GENErating cost Reductions fOr U.S. Medicaid)鈥疢odel introduces most favored nation pricing for Medicaid, while additional mandatory Medicare drug pricing models are under review. Rural health transformation remains a CMS priority, with expectations for further announcements and awards before the end of the year.
We expect 2026 to be another busy year for CMS with more new models being announced, continued policy refinements in the fee-for-service payment systems, and changes in Medicare Advantage based on feedback from the requests for information.
Connect with 红领巾瓜报 Policy Experts
As the new year approaches, uncertainty remains the defining feature of federal health policy. The fate of ACA subsidies, the appropriations process, and a host of other reforms will hinge on negotiations in the coming weeks. For stakeholders navigating these complex dynamics, 红领巾瓜报鈥檚 team of policy experts stands ready to provide guidance, analysis, and support.
When Investment is Good Medicine
In partnership with Sorenson Impact and Catalyst, 红领巾瓜报 co-authored a white paper on the healthcare industry鈥檚 opportunity to move beyond treating illness to creating healthier communities.
This paper outlines the opportunity for health systems and payers to leverage their balance sheets to make impact investments that align with their mission, as well as have business and healthcare value.
Webinar Replay – The ACCESS Model: Essentials for Applicants
This webinar was held on January 22, 2026.
CMS鈥檚 new ACCESS model represents one of the most ambitious federal efforts to modernize chronic care through technology-supported services. This national, voluntary, decade-long model creates a new payment pathway for digital health tools, continuous monitoring, behavioral support, and other tech-enabled interventions that complement traditional care. With beneficiaries able to enroll directly and clinicians eligible for co-management payments, ACCESS introduces a fundamentally different approach to chronic condition management across Medicare.
During this webinar, 红领巾瓜报 and Leavitt Partners experts broke down what is known today, what to expect in the forthcoming Request for Applications, and what organizations can do to prepare. We walked through the model鈥檚 four clinical tracks, outcomes-aligned payments, beneficiary engagement expectations, the TEMPO pilot鈥檚 implications for digital device manufacturers, and how it relates to the CMS Health Tech Ecosystem initiative.
Learning Objectives:
- Understand the ACCESS model鈥檚 goals, structure, and clinical tracks.
- Recognize participant and beneficiary requirements, payment approaches, and data expectations.
- Better understand how the ACCESS and ELEVATE models relate to the CMS-aligned network commitments
- Identify key steps to prepare for the upcoming RFA and assess organizational readiness.
Preparing for Medicaid Community Engagement Requirements鈥擪ey Steps and Opportunities for States and Plans
On December 8, 2025, the Centers for Medicare & Medicaid Services (CMS) issued anticipated on Medicaid community engagement requirements, as established in the 2025 budget reconciliation legislation (P.L. 119-21, referred to as OBBBA). This guidance arrives at a pivotal moment, as states begin budget planning and legislative sessions.
红领巾瓜报 (红领巾瓜报) reviewed the guidance in the context of other policy and financing shifts that are affecting the Medicaid program. This article highlights key takeaways, addresses considerations for implementation, and issues for policymakers and healthcare organizations to track.
Brief Background
Generally speaking, Section 71119 of OBBBA requires states to implement community engagement requirements as a condition of Medicaid eligibility for individuals in the expansion population ages 19鈭�64 who are neither pregnant nor enrolled in Medicare or any other mandatory Medicaid group. The guidance explains the statutory requirements related to how states verify community engagement, notify applicants and beneficiaries, ensure compliance with federal standards as the January 2027 deadline approaches, and other core components of the policy.
Starting January 1, 2027, states must require certain Medicaid expansion applicants to demonstrate community engagement for at least one month and may require up to three consecutive months immediately prior to the month of application. If compliance or exemption status is unverifiable at the time of application, states must provide notice and an opportunity to respond. These enrollees will maintain coverage during the response period. States are also expected to establish clear documentation standards and proactive communication processes for applicants and enrollees.
Three Key Takeaways from the Initial Guidance
1. Organizations must understand the key dates leading up to January 1, 2027
Limited new funding and tight timelines make January 1, 2027, a critical deadline for implementation. Medicaid organizations need to consider, however, the full sequence of events leading up to that date, including providing required advance notification to individuals about the changes and their eligibility status. Documentation and progress tracking are essential, both for compliance and to demonstrate that CMS deadlines are being met.
Although the guidance outlines notice and response requirements, it leaves open critical questions about how states will prevent procedural disenrollments, manage increased appeals volume, and mitigate due process legal risk if eligibility and verification systems fail at scale.
2. Medicaid managed care organizations (MCOs) have a limited role in decision-making but are key to engagement
Medicaid managed care organizations are prohibited from making the determination that an individual has met the community engagement requirement; however, they have an opportunity to support individuals in a range of ways. Recent changes under OBBBA give plans clearer authority to conduct proactive outreach on eligibility and renewal requirements, which strengthens their ability to help members navigate deadlines, reporting expectations, and documentation needs. This capacity will be important because a lack of predictability in enrollment and churn can meaningfully affect the risk profile of plans and, as a result, increase volatility in provider negotiations.
Plans, providers, community organizations, and state and local agencies can collaborate to develop effective engagement strategies, aligned messaging, and ongoing touch points. Helping members understand what is required鈥攁nd when鈥攁nd connecting them with resources to take action will be essential for successful implementation.
3. States and partner organizations need a global view of IT changes and functionality
CMS emphasizes that the eligibility determinations for the community engagement requirements should function seamlessly with new and existing system functionality. Meeting this expectation requires states to have a deep understanding of whether and how policies can be operationalized in their systems without adding administrative burden for individuals and others that engage with the systems.
Meeting federal expectations may be particularly challenging for states with county-based Medicaid systems, as implementing these requirements across multiple jurisdictions may necessitate a longer transition period. The OBBBA includes $200 million in total grant funding for implementation activities in 2026, and states can apply for enhanced federal IT funding at the 90/10 or 75/25 rates for certain costs and activities. Federal resources are otherwise limited, so it is critical that states and partner organizations establish a well-defined strategy to maximize available funding to support the system changes required to implement OBBBA eligibility requirements.
What to Watch
The guidance arrives as many governors begin releasing their budget proposals and planning for upcoming legislative sessions. Although the guidance provides clear information on the overarching parameters and a preliminary road map, certain critical details are forthcoming. State budgets should reflect the requirements and anticipate the need for rapid system and process development.
CMS will issue an interim final rule by June 1, 2026, and states must implement the community engagement requirement no later than January 1, 2027. States must comply with these requirements and act quickly to develop, pay for, and implement new systems, policies, and processes鈥攊deally before the latter half of 2026.
CMS is developing additional guidance in several areas, including:
- Use of reliable data sources听and听how to听satisfy听the definition of engagement听
- Implementation of the requirement to conduct renewals every six months for certain individuals听
- Specific documentation requirements for community engagement听
- Potential role that managed care plans can play听unrelated to听determining听beneficiary compliance听
States and Medicaid organizations should closely monitor these developments and be prepared to adjust their strategies as new information becomes available.
Connect with Us
红领巾瓜报鈥檚 experts are trusted problem solvers, partnering with states to navigate the complexities of community engagement planning, even as requirements and details continue to evolve. Drawing on deep state and federal experience, as well as lessons learned from previous large-scale eligibility reforms, our team helps Medicaid-focused organizations quickly design and implement practical, context-specific strategies that align with OBBBA requirements. Whether it鈥檚 strategy development, system design, or crafting effective messages, 红领巾瓜报 brings a flexible, solutions-oriented approach to maximize continuity of coverage and meet each client鈥檚 unique needs.
Contact听our featured experts below听to discuss how we can support your team in navigating these changes and building effective engagement strategies.听