ACHP Urges CMS to Apply 2026 Hold Harmless Methodology to 2027 MA Star Ratings

ACHP submitted comments to CMS on the interim final rule implementing Medicaid community engagement requirements under the One Big Beautiful Bill Act (CMS-2454-IFC). ACHP supports efforts to promote workforce participation and urged CMS to measure the rule’s success by whether implementation preserves coverage for eligible beneficiaries. The letter recommends CMS eliminate the significant impairment requirement for medical frailty, which adds a subjective second test that risks disenrolling beneficiaries who meet the underlying clinical criteria, and preserve flexible verification pathways while states build data infrastructure. ACHP also urged CMS to issue guidance clarifying how managed care organizations can support implementation through member outreach, education and standardized state-to-plan data sharing.