The federal government recently proposed new restrictions that could cause health coverage loss for more Minnesotans under Medicaid work reporting requirements. We are deeply concerned that the proposed rule ignores the reality of serious and complex medical conditions and restricts Minnesota’s ability to mitigate health coverage loss when implementing work reporting requirements.
During the public comment period where organizations and individuals could weigh in, the Minnesota Budget Project submitted the following letter:
July 30, 2026
Dr. Mehmet Oz
Administrator, Centers for Medicare & Medicaid Services
U.S. Department of Health and Human Services
Attention: CMS–2454–IFC, P.O. Box 8016
Baltimore, MD 21244–8016
RE: Medicaid Program; Community Engagement Requirement for Certain Individuals (CMS-2454-IFC)
Dear Administrator Oz,
Thank you for the opportunity to comment on the Medicaid Community Engagement Requirement interim final rule with comment period (CMS-2454-IFC, referred to throughout this comment as ‘the interim final rule’).
The Minnesota Budget Project is writing in opposition to provisions within the Medicaid work reporting requirements interim final rule that make Medicaid coverage even more difficult to get and maintain.
The Minnesota Budget Project advocates for investments to better the lives and well-being of lower-income Minnesotans and Minnesotans of color, narrow racial divides, and make Minnesota a state where everyone can thrive. Our health care work focuses on the effects of state and federal health care policies on Minnesotans’ ability to live healthy lives and get the care they need.
In Minnesota, roughly 1 million people have health care coverage through Medicaid, also known in Minnesota as Medical Assistance (MA). These include seniors, children, people living with disabilities, and people who work in jobs that don’t pay enough to make ends meet. Through Medicaid, people can afford essential health care services and support.
The interim final rule is expected to cause even more people to lose health care coverage than what was originally anticipated in H.R. 1. After H.R. 1 passed, Urban Institute published a report showing that states could mitigate coverage loss from Medicaid work reporting requirements and other Medicaid changes from H.R. 1 through effective implementation. The report estimated that Minnesota could preserve Medicaid coverage for an additional 59,000 people by implementing work reporting requirements through thoughtful policy decisions. But the interim final rule takes away the state’s ability to make some of these implementation decisions, leading to worse outcomes and likely causing more people to lose their health care coverage.
Changes to medical frailty are restrictive and ignore the reality of serious and complex medical conditions. Changes in the interim final rule will reduce the number of people who can qualify for an exemption to work requirements for reasons of medical frailty. Narrowing this exemption and subjecting these folks to work reporting requirements that will be difficult for them to meet will likely lead to adverse health effects caused by disruptions to their health care.
The guidance significantly limits self-attestation, thereby restricting Minnesota’s ability to implement work reporting requirements in a way that reduces the number of people that unnecessarily lose their coverage. For example, limiting an individual from self-attesting that they have a condition impairing their ability to work in 2028 and beyond will create even more burdensome paperwork for people and states.
The interim final rule creates an unfeasible timeline for states to implement work reporting requirements. These new restrictions come late, as Minnesota works under a compressed timeline to implement Medicaid work reporting requirements starting January 1, 2027.
Minnesotans are all better off when people have the health coverage they need to survive and thrive, but this new federal guidance will put affordable health coverage at risk for many.
Thank you for the opportunity to comment on this important matter.
Jessie Luévano
Policy Analyst