The Office of Management and Budget (OMB) on April 1, 2026, received the interim final rule (IFR) from the Centers for Medicare and Medicaid Services (CMS) entitled: Establishing State Community Engagement Requirements for Certain Individuals Under Section 1902(xx) of the Social Security Act (CMS-2454).

This rule will provide additional requirements upon states in implementing HR 1’s mandatory work (community engagement) requirements on the Medicaid Expansion population for states that have selected to expand Medicaid (41 of 51 states, including the District of Columbia).

We anticipate the rule will include some level of clarification on definitions of caregivers and medical frailty to qualify as an exempted population. We also hope to see guidance requiring extensive state commitment to ex parte, or data validated, renewals. Inclusion of strong requirements around data validation and ex parte redeterminations would eliminate the need for many individuals to repeatedly prove their exemption or community engagement.

This rule is likely to stay at OMB for a somewhat lengthy period of time, though it should be expected before the June 1 deadline imposed on CMS by HR 1.