ASAM Statement: CMS Interim Final Rule on the Medicaid Community Engagement Requirement

Rockville, MD (June 3, 2026) – On June 1, the Centers for Medicare and Medicaid Services (CMS) released an interim final rule defining how states should implement the community engagement reporting requirement for the Medicaid expansion population, including exemptions for individuals with substance use disorder (SUD).

The rule notes that people with SUD (excluding those who are in stable recovery, meaning in recovery for at least five years) are exempt from the requirement, so long as their medical status significantly impairs their ability to comply with the requirement. ASAM is concerned that this new framework of significant impairment creates another onerous barrier to Medicaid coverage for individuals with SUD.

“While ASAM is still reviewing the interim final rule, it is critical that policymakers implement the Medicaid community engagement reporting requirement in a manner consistent with the statutory protections for people with SUD,” said ASAM President Stephen M. Taylor, MD, MPH, DFAPA, DFASAM. “Although ASAM appreciates CMS’ reliance on research that shows achieving stable recovery takes time, requiring a demonstration that one’s SUD also ‘significantly impairs’ their ability to comply with this requirement before that five-year mark is not only ambiguous, but unnecessary and burdensome. ASAM will continue to advocate for an appropriate SUD exemption process to ensure people with SUD can obtain and maintain the Medicaid coverage they need.”

To justify the rule’s categorical exclusion of individuals in stable recovery from the SUD exemption, CMS points to research demonstrating that the risk of SUD recurrence for such individuals is approximately the same as the general population. ASAM maintains that, even accepting CMS’ “significant impairment” framework, applying that same logic consistently would support the categorical inclusion of individuals not in stable recovery within the medically frail exemption for SUD, without requiring them to meet additional requirements.

“This rule also underscores the importance of ensuring that qualified clinicians in all medical settings can provide the full range of addiction treatment options, including methadone for opioid use disorder,” added Dr. Taylor. “Under CMS’ rule, individuals who receive SUD treatment are also exempt from the community engagement reporting requirement when treated by certain nonprofit or publicly operated providers. Given the significant presence of for-profit providers in the methadone treatment space, however, thousands of individuals in stable recovery on long-term methadone maintenance could face unnecessary Medicaid coverage disruptions simply because their treatment is delivered by a for-profit entity.”

About the American Society of Addiction Medicine    

The American Society of Addiction Medicine (ASAM), founded in 1954, is a professional medical society representing over 8,000 physicians, clinicians, and associated professionals in the field of addiction medicine. ASAM is dedicated to increasing access and improving the quality of addiction treatment, educating physicians and the public, supporting research and prevention, and promoting the appropriate role of physicians in the care of patients with addiction. For more information, visit www.ASAM.org.