This week, the Centers for Medicare & Medicaid Services (CMS) released an interim final rule implementing the new community engagement requirements for Medicaid beneficiaries included in healthcare and tax legislation Congress passed last summer. Beginning January 1, 2027, with some exceptions, individuals enrolled in Medicaid must work, volunteer, or participate in job training for at least 80 hours per month to maintain coverage. In response the American Diabetes Association® (ADA) issued the following statement.
The ADA is very concerned about the forthcoming impact of new Medicaid work requirements on healthcare coverage for people with diabetes—nearly half a million of whom are expected to lose access to Medicaid over the next 10 years as a result of H.R. 1. The interim final rule released by the CMS is extremely deferential to states when it comes to defining medical frailty and complex medical conditions that prevent many Medicaid beneficiaries from being able to meet community engagement requirements. People with complications from diabetes living in states that limit exceptions too aggressively could lose access to healthcare services that help them manage their diabetes. We know that low-income adults with diabetes who lack consistent healthcare coverage experience poorer blood glucose (blood sugar) management and require more medications, and individuals with complex medical conditions who lose Medicaid coverage will undoubtedly experience even worse, more costly health outcomes.
We are pleased, however, that the CMS decided to limit paperwork and reporting requirements in 2027 for individuals who qualify for an exception because they are medically frail and/or have a complex medical condition that precludes them from meeting the 80-hour standard. We urge the CMS to extend the period during which Medicaid beneficiaries who qualify for an exception may self-declare, which will also benefit healthcare professionals who face a greater administrative burden managing Medicaid patients with complex medical conditions. We look forward to working with the CMS to protect this vulnerable population from coverage losses as community engagement requirements and other Medicaid policy changes go into effect in the coming years.
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About the American Diabetes Association
The American Diabetes Association (ADA) is the nation’s leading voluntary health organization fighting to end diabetes and helping people thrive. This year, the ADA celebrates 85 years of driving discovery and research to prevent, manage, treat, and ultimately cure diabetes—and we’re not stopping. There are over 155 million Americans living with diabetes or prediabetes. Through advocacy, program development, and education, we’re fighting for them all. To learn more or to get involved, visit us at or call 1-800-DIABETES (800-342-2383). Join us in the fight on Facebook (American Diabetes Association), Spanish Facebook (Asociación Americana de la Diabetes), LinkedIn (American Diabetes Association), and Instagram (@AmDiabetesAssn). To learn more about how we are advocating for everyone affected by diabetes, visit us on X (@AmDiabetesAssn).
