ASAM provides advice on complying with new Medicaid work requirement rules

On June 1, 2026, the Centers for Medicare and Medicaid (CMS) issued an interim final rule (IFR) to implement community engagement/work reporting requirements as a condition of Medicaid eligibility for certain populations in Medicaid expansion states (see ADAW https://onlinelibrary.wiley.com/doi/10.1002/adaw.34575 ). Treatment providers, Medicaid recipients, and states are struggling to understand how these rules affect them. This month the American Society of Addiction Medicine (ASAM) issued a FAQ explaining how the IFR affects addiction patients. Among the issues explained are how patients in active treatment are exempted from the work requirements of Medicaid. “The rule excludes from reporting requirements individuals who are participating in an addiction treatment/rehabilitation program. It treats them as specified excluded individuals (not applicable individuals), meaning they are not subject to the community engagement requirement. However, the exclusion is based on participation in a qualifying treatment/rehabilitation program. States must first try to verify participation using reliable state‐available information, such as claims, payment data, encounter data, or other records. If those sources are unavailable or insufficient, the state may request additional information or documentation. The rule uses the Food and Nutrition Act's definition of a drug addiction or alcoholic treatment and rehabilitation program: a program conducted by a private nonprofit organization, institution, or publicly operated community mental health centers, that provide treatment that can lead to rehabilitation. States are responsible for determining whether a program meets the definition.” For the ASAM FAQ, go to https://www.asam.org/news/detail/2026/06/08/faq–medicaid‐community‐engagement‐requirements—what‐new‐rules‐mean‐for‐patients‐with‐a‐substance‐use‐disorder