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Medicaid Coverage

Protecting access to mental and behavioral health services for Medicaid enrollees

APA Services submits comments to the Centers for Medicare and Medicaid Services concerning new Medicaid work/community engagement requirements

Last updated: October 19, 2026 Date created: July 31, 2026 2 min read
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American Psychological Association. (2026, October 19). Protecting access to mental and behavioral health services for Medicaid enrollees. https://www.apaservices.org/advocacy/news/protecting-health-services-medicaid-enrollees

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On July 31, 2026, APA Services submitted its comment letter on Medicaid Community Engagement Requirements (CMS-2454-IFC) (PDF, 311KB)opens in new window in response to the Centers for Medicare & Medicaid Services (CMS) Interim Final Rule (IFR) concerning the new work and community engagement requirementsopens in new window (WR/CE) enacted under last summer’s One Big Beautiful Bill Act (H.R. 1). Under H.R. 1, many Medicaid enrollees must generally complete a certain number of hours of work, community service, or education to be eligible for Medicaid, or meet a specified exemption to these requirements. H.R. 1 required CMS to issue this IFR to provide more details on this requirement, including how enrollees are expected to document their compliance with this requirement or that they meet an exemption from this requirement.

APA Services expressed deep concern in its July 31 response that the IFR, if finalized as written, will create onerous hurdles that put coverage at risk for many people with mental health conditions and substance use disorders (MH/SUD). As a result, APA Services calls on CMS to revise the IFR to protect the millions of people who rely on Medicaid for life-saving MH/SUD care.

APA Services also urged CMS to provide guidance to states on eligibility determinations, as well as details about exemptions from the WR/CE requirements, reporting requirements, verification processes, and implementation standards. Under H.R. 1, states are compelled to take the WR/CE IFR and develop mechanisms, infrastructure and strategies to implement and support these changes that are scheduled to take effect on January 1, 2027, with three states (Nebraska, Montana, and Iowa) implementing the requirements earlyopens in new window.

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APA Services highlighted to CMS four core areas of concern with the IFR:

  • the IFR exceeds its statutory authority by requiring states to also evaluate whether an individual’s condition “significantly impairs” their ability to work;
  • states can accept self-attestation in 2027, but CMS limits reliance on self-attestation beginning in 2028;
  • additional time is needed to ensure timely publication of implementation data and approving good-faith state waivers; and
  • there is a need for robust engagement with other provider and patient groups.

APA Services will be unveiling an engagement strategy stemming from our comments and provide you with additional resources that build on our Medicaid toolkit for our State, Provincial, and Territorial Psychological Associations and other state leaders to engage with relevant stakeholders (e.g., State Medicaid Authorities, State Medicaid Advisory Committees and the State Beneficiary Advisory Councils, et al.) to protect access to life-saving MH/SUD services. 

For more information, email Julio C Abreu.

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