Don’t Let H.R. 1’s New Medicaid Expansion Processes Overburden People with SUD, Coalition Writes to HHS

ASAM and a coalition of organizations dedicated to improving healthcare for Americans with substance use disorders and mental health conditions sent a comment letter to HHS Secretary Robert F. Kennedy, Jr., calling for the agency to allow flexible state implementation of H.R. 1’s “Community Engagement” provisions, consistent with the clear statutory direction.  

H.R. 1, signed into law on July 4, 2025, introduced an 80-hour monthly work or community engagement requirement for individuals to be eligible for Medicaid expansion.  

However, the law includes mandatory exemptions to the work requirement to protect certain populations, including individuals with substance use disorders, disabling mental health conditions, disabilities, and serious or complex medical conditions, as well as individuals who were recently released from incarceration. Further, the coalition notes that the law requires states to regularly verify compliance only for “applicable individuals,” whereas individuals who meet the exemptions are deemed compliant by law, and states have the discretion to determine whether additional verification is necessary. 

The coalition writes that the law also allows for “significant flexibility for states to prioritize the least burdensome options for determining eligibility and compliance for ‘applicable individuals’ and adoption of the most efficient and effective exemption methods.”  

Read the letter here.