The American Cancer Society Cancer Action Network (ACS CAN) appreciates the opportunity to comment on the interim final rule with comment (IFC) regarding the Medicaid program and community engagement requirement for certain individuals, filed on June 1, 2026. ACS CAN is making cancer a top priority for public officials and candidates at the federal, state, and local levels. ACS CAN empowers advocates across the country to make their voices heard and influence evidence-based public policy change, as well as legislative and regulatory solutions that will reduce the cancer burden. As the American Cancer Society’s nonprofit, nonpartisan advocacy affiliate, ACS CAN is more determined than ever to end cancer as we know it, for everyone.
As the Department of Health and Human Services (HHS) and the Centers for Medicare and Medicaid Services (CMS) continue work with states to implement the Working Families Tax Cut,[i] we strongly encourage you to ensure eligible people can access and maintain health coverage – because everyone needs health coverage to prevent, diagnose, treat, and survive cancer. While we appreciate the careful consideration CMS has given to how the IFC will impact some populations under these new requirements, we have serious concerns about the rule. We believe major changes are needed to ensure that individuals who are subject to these new requirements can successfully meet them and those who qualify for exemptions are effectively and efficiently exempted. Specifically, in our comments below, we urge CMS to make the following important changes in the final rule:
- Change the definition of medical frailty to align with the statute, removing the requirement for an individual to prove they are unable to meet community engagement requirements in addition to having a serious or complex health condition;
- Remove the limitations on state use of self-attestation to verify information about compliance or exception to community engagement requirements; and
- Remove the application of a 1-month lookback period for short-term hardship exceptions so that individuals applying for the exception will not experience gaps in coverage.
We urge CMS to issue a final rule with these changes as quickly as possible to minimize coverage loss and coverage gaps for vulnerable Medicaid populations, including cancer patients. Additionally, we strongly urge the Secretary to use the authority given in federal statute to grant those states who apply the flexibility to delay implementation of certain pieces of these new requirements if their systems are not ready by the statutory deadline. The consequences of rushed implementation include erroneous coverage loss, and for a cancer patient this consequence could be deadly.
More detailed comments available to download in PDF form.
