Ranking members of two important Senate committees in an October 21, 2025 letter to the Centers for Medicare and Medicaid Services (CMS) outlined concerns with states’ ability to comply with rules that were previously effective, but more recently faced partial moratoriums on enforcement with the passage of HR 1.

Over seven pages, Sens. Ron Wyden (D-OR) and Jeff Merkley (D-OR) voiced concerns with lack of CMS guidance around provisions finalized by rule making. The letter seeks clarification on CMS’ view of compliance or optional pursuit by states of specific provisions in the final rules for Medicare Savings Program, Medicaid Eligibility and Enrollment, and the Nursing Home Minimum Staffing Rules.

The letter outlines key provisions in the laws that were not subject to an enforcement moratorium and elevates the narrative that states face unprecedented amounts of interpretation to comply with HR 1, CMS issuance of additional guidance on previously enacted rules is a necessary service owed to states.

The full letter is available here