The following public comment was submitted by Bethany Pray on behalf of CCLP on July 31, 2026, to the Centers for Medicare & Medicaid Services and the Department of Health and Human Services in opposition to the Interim Final Rule (IFR), “Medicaid Program; Community Engagement Requirement for Certain Individuals,” CMS-2454-IFC.
Since August 2025, CCLP has convened a workgroup of community-based organizations, health providers and clinics, community members, and government partners to discuss implementation of community engagement requirements. These comments are informed by that workgroup, as well as by conversations with partners in the healthcare industry and in government, among advocates and legal partners, and with individual Coloradans.
The IFR imposes an enormous number of complex requirements—on individuals, employers, educations, clinics and hospitals, and states—that are absent from H.R.1. It sets states up for failure and ultimately for financial penalties that are likely to contribute to even more Americans losing coverage. We asked that the rule be withdrawn and revised to comply with H.R. 1.
For more information see the proposed rule on the Federal Register.





Skills2Compete Public Comment on the Medicaid Interim Final Rule
Public Comment, Publications