Medicaid Community Engagement Requirement

Beginning January 1, 2027, most states will be required to implement H.R. 1’s Medicaid community engagement requirement. Under the new rule, millions of Medicaid beneficiaries will need to regularly complete 80 hours of work, education, or volunteer service in a month to maintain coverage.

However, states face significant challenges in operationalizing the new rule.

While H.R. 1 includes a “medically frail” exclusion for certain individuals, including people with a substance use disorder (SUD) or “disabling mental disorder,” states must determine how to define these conditions and establish processes for identifying individuals who qualify for an exclusion.

States face unique challenges in appropriately capturing people with behavioral health conditions, which can vary in severity and may not always be readily identifiable through traditional eligibility or claims data. Without clear, workable approaches, individuals with qualifying behavioral health conditions could be incorrectly required to meet the community engagement requirement – and risk losing their Medicaid coverage.

To support states in navigating these challenges, NABH has been working alongside other leading healthcare organizations — in court and beyond — to protect access to coverage for those who rely on it. 

NABH also developed a suite of resources to help members advocate for implementation approaches that protect access to behavioral healthcare:

• Member Brief
  An overview of NABH’s recommendations and resources. We recommend starting here before diving into the more detailed materials.
• Introductory Letter Template
  A customizable template for introducing the State Implementation Guide (below) to state Medicaid officials.
• State Implementation Guide
  Practical recommendations, actionable steps, and tools that members can share directly with states to support implementation of the community engagement requirement. These tools include:
  • Definitions of key terms (State Implementation Guide, Page 9)
  • Code list to identify individuals with qualifying behavioral health conditions
  • Medical frailty screener (State Implementation Guide, Page 18)
• Member Manual
  Guidance for advocating with state officials on implementation of the State Implementation Guide.
• Webinar Recording and Slides
  Missed our webinar? Learn more about the community engagement requirement, NABH’s behavioral health resources, and strategies for engaging state Medicaid officials.