On June 1, CMS published an interim final rule outlining how states should carry out work requirements under which low-income, nonpregnant adults ages 19 to 64 must work, perform community service or attend school for at least 80 hours a month to keep Medicaid coverage.
To qualify for a medical frailty exemption to the rule, Medicaid beneficiaries must first fall into one of five diagnostic categories: blindness or disability, substance use disorder, a disabling mental disorder, a physical or developmental disability that impairs activities of daily living, or a serious or complex medical condition. That condition must then “significantly impair” the person’s ability to meet the 80-hour monthly requirement.
Democratic governors and attorneys general from 25 states and Washington, D.C., sued the Trump administration June 29 over the rule, arguing the policy narrows exemptions for medically frail beneficiaries and could strip coverage from eligible patients.
Six cancer center leaders told Becker’s how the work requirements may affect their patients, and what their organizations are doing to stay ahead of it.
Editor’s note: Responses have been lightly edited for clarity and length.
Question: How is your organization preparing to support cancer patients who may face new eligibility or reporting obligations?
Sudha Bommidi. Vice President of AdventHealth Cancer Institute (Altamonte Springs, Fla.): AdventHealth is committed to helping patients access the care they need, particularly during vulnerable periods of illness and recovery. For cancer patients, Medicaid work requirements may create additional administrative challenges at a time when many individuals are navigating active treatment, recovery, long-term side effects or other health-related barriers to employment. At AdventHealth, we already help patients navigate Medicaid and other local, state and county assistance programs, and we plan to incorporate any new requirements into our existing financial counseling and patient navigation processes.
Our focus is on minimizing barriers to care. This includes helping patients obtain appropriate medical documentation when needed, educating them about eligibility requirements and connecting them with resources that support continued coverage. Maintaining access to care is critical for cancer patients and we will continue working alongside patients to help ensure coverage disruptions do not interfere with treatment, recovery or long-term survivorship care.
David Cohn, MD. COO and Gynecologic Oncologist at The Ohio State University Comprehensive Cancer Center — Arthur G. James Cancer Hospital and Richard J. Solove Research Institute (Columbus, Ohio): As a practicing cancer surgeon and hospital administrator, my primary concern is the potential impact of new Medicaid eligibility and reporting requirements on patients undergoing cancer treatment. A cancer diagnosis often creates significant physical, emotional and financial burdens. Patients may experience periods of disability, reduced work capacity, frequent medical appointments and treatment-related complications that make compliance with additional administrative requirements challenging.
Healthcare organizations are preparing by strengthening financial counseling, patient navigation, social work and benefits assistance programs to help patients understand and maintain eligibility. We anticipate an increased need for proactive outreach, education, documentation support and coordination with state agencies to minimize disruptions in coverage.
The greatest risk is not necessarily the policy itself, but the possibility that eligible patients lose coverage because of reporting challenges, administrative complexity or gaps in communication. Even short interruptions in insurance coverage can delay diagnostic testing, treatment, supportive care and follow-up services that are critical to cancer outcomes.
As these requirements are implemented, healthcare systems, policymakers and community partners must work together to ensure that patients facing serious illnesses retain timely access to care while maintaining the policy’s broader goals of encouraging workforce and community engagement.
Blake Herring, MSN, RN. Associate Chief Service Lines for Cancer Services at UVA Comprehensive Cancer Center (Charlottesville, Va.): For cancer patients, my biggest concern is not whether they qualify for an exemption, but whether they can successfully navigate the reporting and administrative requirements while undergoing treatment. Many patients are already dealing with complex care needs, financial stress and frequent appointments, so health systems will need to proactively identify at-risk patients and help prevent avoidable coverage disruptions that could delay care. At UVA Health, we are working closely with our financial counselors and supportive care teams to ensure patients have the guidance and resources they need to navigate any new eligibility or reporting requirements and maintain access to their care.
Noel Juaier. Vice President of Patient Financial Services at Stanford Health Care (Palo Alto, Calif.): The determination dates for working requirements will likely not be consistent and may not be well known to providers via real-time eligibility queries. This means that patients will likely lose coverage, potentially retroactively, without proactive notification to the provider. In addition, these patients will also likely lose other benefits that would presumptively qualify them for charity, such as SNAP.
Simply put, these patients will become self-pay. It will cause care delays as we determine how we can find alternative sponsorship or qualify the patients for presumptive or full charity. Finding sponsorship or qualifying for financial assistance will require outreach and follow-up. While Stanford continues to implement technology to streamline the financial assistance processes, we expect it will result in a larger administrative burden for providers and health systems and will impact our financial metrics.
Considerations providers need to address for cancer patients, to proactively manage the requirements and maintain Medicaid eligibility over the continuum of care:
- Careful monitoring of eligibility for Medicaid patients — this may mean more frequently checking eligibility to ensure continuity of coverage
- Work with eligibility vendors to determine how they can support identifying and surfacing redetermination, re-enrollment and renewal dates in the EHR
- Ways to identify patients that will qualify for the exemption — this includes documenting patient conditions that may help meet the medical frailty criteria
- Proactive engagement with patients to ensure they understand their role in ensuring continuous coverage
- Build robust and responsive processes when eligibility lapses
- Direct eligibility loss with financial counseling and financial assistance processes
- Consider engaging with an eligibility vendor to help patients navigate the process to re-establish eligibility
- Identify potential losses of secondary Medicaid coverage
- Ensure that patients who qualify for Medicaid via Qualified Medicare Beneficiary do not lose coverage, as this can create additional leakage and serious financial toxicity for fixed-income patients
How Stanford is preparing to support patients who may face new eligibility or reporting obligations:
- Engaging with our eligibility vendor to ensure that the workflows and processes will handle an expected increase of patients losing Medicaid
- Working with our technology partners to detect re-enrollment dates to proactively manage patients at risk of Medicaid eligibility loss
- Evaluating how financial counseling and financial assistance processes need to change to address coverage loss
- Updating our financial assistance policies and refining procedures to account for ongoing regulatory changes, including the effective dates of the HR 1 requirements and several key California regulatory changes
- Continuing work on workflows and technology to improve patient engagement for navigating their care and coverage options
Michaela Newman, MSN, RN. Executive Director of Operations for Cancer Services at Nebraska Medicine’s Fred & Pamela Buffett Cancer Center (Omaha, Neb.): From a cancer perspective, Medicaid work requirements introduce a new layer of complexity for cancer patients, many of whom are actively undergoing treatment, managing significant side effects or navigating survivorship. Even short-term lapses in coverage due to reporting challenges or eligibility changes could disrupt continuity of care, delay treatment and ultimately impact outcomes.
At our Fred & Pamela Buffett Cancer Center at Nebraska Medicine, we are proactively preparing by strengthening patient navigation and financial counseling support to help individuals understand and meet new requirements. We are also evaluating workflows to identify patients at risk for coverage disruption and exploring partnerships with community organizations to provide additional support around employment resources and reporting assistance. We are leveraging analytics and care pathways to flag high-risk populations early and intervene before coverage lapses occur. Equally important is our advocacy and collaboration with state and policy stakeholders to advocate for streamlined, automated and clinically aligned exemption processes that reduce administrative burden, ensuring implementation aligns with oncology patients’ needs and minimizes unintended impacts.
Theodoros Teknos, MD. President and Scientific Director of University Hospitals Seidman Cancer Center and Deputy Director of the Case Comprehensive Cancer Center (Cleveland): Medicaid patients typically constitute anywhere from 5% to 20% of the population treated in urban cancer centers. The proposed Medicaid work requirements are predicted to result in loss of coverage from a low of 20% to as many as 40% of Medicaid enrollees. The negative impact on the health of our communities and the financial stability of cancer centers nationwide requires immediate attention.
At University Hospitals Seidman Cancer Center, working with our Chief Health Impact Officer, Celina Cunanan, MSN, APRN-CNM, we are proactively reaching out to this vulnerable community and offering opportunities for volunteerism, education, as well as other forms of assistance to ensure that our patients remain Medicaid eligible. These efforts are being coordinated with local municipalities and other healthcare systems in our region to maintain the health of the communities we serve.
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