AMGA Urges CMS to Strengthen Safeguards Against Coverage Losses in Medicaid Community Engagement Rule

Cites member survey data showing providers already absorbing significant financial strain from Medicaid funding changes

Alexandria, VA — AMGA today called on the Centers for Medicare & Medicaid Services (CMS) to adopt stronger protections against unintended coverage losses resulting from Medicaid community engagement requirements. 

In comments on CMS’ proposed rule (CMS-2454-IFC Medicaid Program; Community Engagement Requirement for Certain Individuals), AMGA noted the agency’s own estimates attribute nearly 43% of projected coverage losses under the rule to procedural disenrollment rather than an individual’s actual failure to meet the community engagement requirement. The Congressional Budget Office has separately estimated that the requirement could increase the number of uninsured Americans by as many as 5.3 million.

“Medicaid’s community engagement requirement should encourage active participation in the program, not become a mechanism for eligible people to lose coverage simply because they couldn’t navigate a new paperwork process,” said Jerry Penso, MD, MBA, president and CEO of AMGA. “AMGA members are committed to caring for their communities, but they cannot do so if patients are disenrolled for procedural reasons rather than substantive ones and if providers are left to absorb the resulting costs without adequate time or guidance to prepare.”

AMGA’s letter makes three primary recommendations to CMS:

• Strengthen coverage safeguards. CMS should adopt additional protections to minimize procedural coverage losses and establish a public system to track and report on disenrollments and healthcare access.
• Reduce provider burden tied to the medical frailty exclusion. AMGA recommends extending the medical frailty exclusion period from one year to five years and issuing standardized federal guidance to help states and providers apply the exclusion criteria consistently.
• Extend the implementation timeline. AMGA urges CMS to provide at least an additional 12 months of transition time, given the number of other significant Medicaid policy changes already underway.

The letter also draws on findings from AMGA’s 2026 Medicaid member survey to illustrate the financial pressures many provider organizations are already experiencing. According to the survey, 38% of respondents have already eliminated patient services, 21% have already closed or restructured facilities, and 50% have already reduced staff in response to other recent Medicaid funding changes, with even larger shares anticipating further cuts. AMGA argues that these existing pressures leave little capacity to absorb the additional uncompensated care costs which further coverage losses under the community engagement requirement would likely create.

“Our members are being asked to do more with less at every turn,” Penso added. “Compounding new coverage losses on top of funding reductions that are already forcing service and staffing cuts puts patient access at real risk.”

The letter is available on AMGA’s website.
 

###

About AMGA
AMGA is a trade association leading the transformation of healthcare in America. Representing multispecialty medical groups and integrated systems of care, we advocate, educate, innovate, and empower our members to deliver the next level of high-performance health. AMGA is the national voice promoting awareness of our members’ recognized excellence in the delivery of coordinated, high-quality, high-value care. More than 175,000 physicians practice in our member organizations, delivering care to one in three Americans.