Medicaid Program; Community Engagement Requirement for Certain Individuals
CMS has issued an interim final rule requiring certain Medicaid beneficiaries to demonstrate community engagement (work requirements) as a condition of eligibility, with state implementation mandated by January 1, 2027. While not directly targeting OPOs, this rule could reduce the Medicaid-insured donor and recipient population if beneficiaries lose coverage due to non-compliance, potentially affecting referral volumes and recipient eligibility tracking. OPO medical directors and hospital development staff should monitor how state-level implementation affects donor hospital patient populations and waitlisted recipients.
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