The U.S. Conference of Catholic Bishops (USCCB) is calling for "compassion, simplicity, and access to care" to be reflected in the final rule that enforces work requirements for people who receive Medicaid benefits.
The USCCB — along with the Catholic Health Association and Catholic Charities USA — sent a joint letter to the Centers for Medicare & Medicaid Services (CMS) on July 31 to highlight their shared concerns about the final rule before it is fully implemented on Jan. 1, 2027.
The bishops warned the Medicaid work-requirement rule could strip coverage from medically frail patients, add burdensome documentation standards, and create an unrealistic timeline that states and providers cannot meet.
Although the rule has already been adopted, the USCCB is urging CMS delay implementation and make changes that broaden the medical frailty and short-term hardship exceptions, ease verification requirements for patients, and better educate patients on rules to prevent any losses in coverage for eligible people.
"We are profoundly concerned that [the] requirements … will result in coverage loss for eligible individuals who rely on Medicaid to address their health care needs and to achieve their highest possible degree of self-sufficiency," the joint letter states.
The rule requires at least 80 hours of work per month for nonexempt people or another type of community engagement, such as volunteering, job training, or education. Recipients can combine different forms of work and community engagement to reach the 80-hour requirement.
Proposed delay and changes
States must implement the work requirements by Jan. 1, 2027, and the joint letter urges a delay because the rule forces states to "implement significant new operational processes," which the letter warns could lead to mistakes "within a compressed implementation timeframe."
"Launching these requirements before states are fully prepared increases the risk that eligible patients will lose Medicaid coverage because of administrative barriers rather than because they are no longer eligible," the letter states.
The three organizations are also concerned that the medical frailty exclusion — which exempts people with certain disabilities and health conditions from work requirements — is "too narrow."
To qualify for the exclusion, a person must verify that he or she has the condition and that the condition "significantly impairs their ability to comply with the work and community engagement requirements," the letter notes. The three Catholic organizations encouraged CMS to exempt people based on the condition alone rather than requiring they demonstrate that the impairment prevents them from work.
The letter also expressed concerns about the language that enforces the short-term hardship exception, warning that a person would need to demonstrate that hardship in the month before the exception can be applied.
"We recommend … [ensuring] that a short-term hardship exception may satisfy an individual's work and community engagement requirement obligation for the month of the hardship event, including where that month is the month of application or renewal, without requiring a separate showing of compliance during a prior review period," the letter adds.
They also caution that the verification and documentation requirements shift too much of the burden to patients and providers.
"Experience from prior work and community engagement requirement demonstrations in several states shows that administrative friction, rather than ineligibility, causes many otherwise eligible individuals to lose coverage," the letter states.
"Each additional document request, third-party verification requirement, or delay in obtaining records increases the risk that eligible individuals will lose Medicaid coverage for procedural reasons," it adds.
The letter also encourages CMS to ensure states "have adequate time to develop, test, and validate" their communications with patients, ensuring they understand the new rules before implementation.
"States should not disenroll beneficiaries until they have demonstrated that notices are effective in helping eligible individuals understand and successfully navigate the new requirements," the letter adds.
In the letter, the three organizations said they are "committed to supporting the implementation of work and community engagement requirements in a manner that is legally compliant, operationally sound, and protective of the patients that the exclusion and exception framework are designed to serve."
CMS did not immediately respond to a request for comment from EWTN News.
