Letter to CMS: Guidance on Community Engagement Requirements for Individuals with SUD

Effective January 1, 2027, the budget reconciliation bill H.R. 1 requires adults aged 19-64 enrolled in Medicaid expansion to meet new "community engagement" reporting requirements to maintain eligibility, with exemptions for "specified excluded individuals." This includes individuals with substance use disorders (SUD). 

In anticipation of the community engagement requirement, ASAM and fellow organizations with the Mental Health Liaison Group (MHLG) issued a letter to the Centers for Medicare & Medicaid Services (CMS) Administrator, Dr. Mehmet Oz, that outlines clear guidance on how to implement this requirement while still protecting coverage for Americans living with SUD.

The organizations recommend that CMS do the following:

• Require states to monitor and report the effect of community engagement requirements on individuals with mental health and SUD.
• Engage advocates and beneficiaries in the implementation and education process.
• Provide states with guidance that protects access and ensures that eligible individuals do not lose coverage unnecessarily. 

Such actions are necessary to protect access to care for Americans with SUD and reliant on Medicaid. 

Read the full letter with further recommendations here.