Medicaid Implementation, Kennedy's Testimony, and What's Next for USPSTF

This week's issue examines the early implementation challenges of Medicaid community engagement requirements, new signals from Secretary Kennedy on AHRQ and the USPSTF, and more.

In this edition of AcademyHealth’s Situation Report, we examine the early implementation challenges facing states as they begin operationalizing Medicaid community engagement requirements under H.R. 1, with significant implications for coverage continuity and due process protections. We also review new signals from Secretary Kennedy on the future of the USPSTF and AHRQ following his testimony before Congress, and track ongoing concerns about agency independence at CDC. Additional developments include the launch of the CMMI ACCESS Model and what it means for Medicare beneficiaries, and a roundup of newly introduced legislation aimed at reducing patient financial burdens.

In today’s issue:

· Due Process Risks Intensify as States Implement Medicaid Community Engagement Requirements

· Secretary Kennedy’s Testimony before the House Ways and Means Committee brings Cautious Optimism and Concern

· CDC Nomination Brings Qualified Leadership, but Questions About Agency Independence Remain

· CMMI ACCESS Model Raises Concerns About Efficiency for Medicare Patients

· To Reduce Health Care Waste, CMS Must Focus on How Care is Delivered

· New Episode: Aaron Carroll on Why Work Requirements Could Cost More Than They Save

· Roundup of Newly-Introduced Bills

Due Process Risks Intensify as States Implement Medicaid Community Engagement Requirements

As states move to implement Medicaid community engagement requirements under H.R. 1, concerns are growing about whether existing administrative systems can meet constitutional due process standards. Community engagement rules condition Medicaid coverage on documenting at least 80 hours per month of work or other qualifying activities, such as employment, job training, education, or volunteering, unless an individual qualifies for a health-related, family, or hardship-based exemption. This would require more frequent eligibility redeterminations, substantially increasing the complexity of Medicaid enrollment and renewal. Without strong procedural safeguards, such as clear, individualized notice, meaningful opportunities to appeal, and continued coverage during disputes, states risk widespread coverage losses.

Community engagement requirements add layers of fact intensive determinations to an already complex eligibility process, particularly for adults with serious or chronic health conditions who may qualify for exemptions. Because eligibility must be reassessed every six months, states must repeatedly evaluate compliance, hardship exceptions, and health‑related exemptions using data systems that are often outdated or incomplete. This increases the likelihood of administrative error and places significant burden on beneficiaries to produce documentation, even when health conditions themselves create barriers to compliance.

Recent federal court rulings arising from the post‑COVID Medicaid unwinding highlight the stakes of adding new procedural conditions to eligibility. Courts found that vague, inaccurate, or incomprehensible notices contributed to large‑scale coverage losses unrelated to true eligibility, underscoring that procedural failures can drive disenrollment. These cases offer a warning as states layer community engagement requirements onto Medicaid eligibility determinations under H.R. 1.

As Medicaid work and community engagement policies expand, researchers play a critical role in evaluating how administrative design affects coverage continuity, error rates, appeals, and health outcomes, especially for people in fair or poor health who rely most on Medicaid. Evidence will be essential to understanding whether these policies can be implemented without undermining access to care or fundamental due process protections.

Secretary Kennedy’s Testimony before the House Ways and Means Committee brings Cautious Optimism and Concern

Last week, U.S. Health and Human Services (HHS) Secretary Robert F. Kennedy Jr. Made several trips to Capitol Hill to speak before the U.S. House Committee on Ways and Means, and the House Appropriations health subcommittee to testify about the FY27 President’s Budget Request. In response to the hearings, AcademyHealth’s President and CEO, Aaron Carroll submitted testimony to support the Agency for Healthcare Research and Funding (AHRQ) to the House Labor, HHS Subcommittee.

The House Appropriations hearing heard testimony from Secretary Kennedy as he defended the confirmation of Casey Means-- the Surgeon General nominee, which has drawn scrutiny from medical and public health organizations. During the multiple hearings, Secretary Kennedy was steadfast on highlighting key priorities of the Trump administration ahead of the upcoming midterm elections in November. The Secretary focused on the administration’s promotion of healthier food, and reducing fraud, waste, and abuse. Committee members raised questions about the administration’s approach to fraud enforcement, including the prioritization of recipient-focused versus provider-focused penalties.

Secretary Kennedy’s testimony last week offered new insights into upcoming changes within HHS. Compared to his previous comments in July 2025, where he mentioned a plan to purge all 16 members of the U.S. Preventive Services Task Force (USPSTF), during last week’s hearing, Secretary Kennedy confirmed that changes would be coming soon to the USPSTF. In response to his remarks on AHRQ and the USPSTF, AcademyHealth issued a statement, calling for clarity on Secretary Kennedy’s comment that “[w]e are now bringing new members on who have a clear mission.” With the assumption that the Secretary must mean that the USPSTF’s current mission is to decide “evidence-based recommendations about preventive services such as screenings, behavioral counseling, and preventive medications.” As the professional home for health services research, AcademyHealth is steadfast in its commitment to working with Congress and the Administration to guarantee that AHRQ and the USPSTF are able to carry out their statutory missions.

With regards to concerns about access to care in rural communities, Secretary Kennedy pledged to implement the Rural Health Transformation Fund. The Fund, which would come after historic cuts to Medicaid, that the Secretary recognizes as a “crisis,” is set to direct $50 billion over five fiscal years to promote rural health innovation, infrastructure development, investment in the workforce, and strategic partnerships.

The release of the FY27 President’s Budget Request sparked many concerns for the field of health services research, as it includes additional HHS restructuring and placing a 15 percent cap on indirect costs. Secretary Kennedy’s Capitol Hill visits offer new insights into the administration’s plans for advancing their Make America Health Again (MAHA) initiative.

CDC Nomination Brings Qualified Leadership, but Questions About Agency Independence Remain

The nomination of Erica Schwartz to lead the Centers for Disease Control and Prevention has been met with cautious optimism from public health experts, who note her scientific credentials and lack of public ties to anti‑vaccine movements. At the same time, concerns remain about whether the incoming CDC director would have sufficient autonomy to lead the agency amid ongoing political influence from Health and Human Services Secretary Robert F. Kennedy Jr., particularly following the recent upheaval around vaccine policy and advisory committee governance.

Schwartz’s nomination follows the firing of former CDC Director Susan Monarez after a dispute over vaccine recommendations and comes amid continued restructuring of the Advisory Committee on Immunization Practices (ACIP). Recent changes to ACIP’s charter have narrowed required expertise and shifted its focus, while reports of delayed publication of vaccine effectiveness research have raised additional concerns about scientific independence. Observers note that the CDC has also seen a sharp increase in political appointees embedded within the agency, a departure from long‑standing norms.

While supporters point to Schwartz’s experience in federal public health and crisis response, critics warn that her effectiveness will depend less on credentials than on whether she is empowered to follow evidence without interference. Leadership stability and institutional independence at CDC are foundational to public trust, data integrity, and evidence‑based policy. Researchers should closely track how governance changes affect advisory processes, publication timelines, and the use of scientific evidence in decision‑making.

CMMI ACCESS Model Raises Concerns About Efficiency for Medicare Patients

In December 2025, the Center for Medicare and Medicaid Innovation (CMMI) announced that the creation of a 10-year payment program, Advancing Chronic Care with Effective Scalable Solutions (ACCESS) to implement the use of technology to aid in the treatment of chronic diseases. Last week, CMS announced that they have accepted 150 leading health care organizations to participate in the launch of the ACCESS Model that is set to run from July 5, 2026, through June 30, 2036. Of these 150 organizations, most have not previously served Medicare beneficiaries, which observers note may increase the complexity of claims processing and raise compliance questions for organizations new to Medicare billing.

The goal of the ACCESS Model is to introduce Medicare beneficiaries to additional technology-supported care options to help manage several chronic conditions across four categories: (1) early cardio-kidney-metabolic, (2) cardio-kidney-metabolic, (3) musculoskeletal, and (4) behavioral health. These conditions include chronic kidney disease, depression and anxiety, obesity, diabetes, and hypertension which impact over two-thirds of Medicare recipients. The Model will also be testing a new payment option, Outcome-Aligned Payments, to reward health outcomes instead of required activities. Medicare providers enrolled in the Model will receive outcome-aligned payments that will cover the cost of the technology, if a qualifying patient achieves clinically significant outcomes, such as lowering their blood pressure.

Private payors representing more than 165 million members across commercial plans, Medicaid, and Medicare Advantage, have agreed to support the Model’s payment approach. Commercial payers such as Cigna, Centene, CVS Health, Humana, multiple Blue Cross Blue Shield state plans, and others have agreed to issue outcome-aligned payments for implementing the health care technology in their practice. The 150 health care organizations represent a range of tech-enabled health care companies including: Headspace, Sondermind, an AI doctor startup, Doctronic, Noom, Weight Watchers, a healthy aging startup Bold, and many more.

CMS will continue to review health care organizations on a rolling basis, and those who want to be considered for the Model’s first performance period are encouraged to apply by May 15, 2026. As the countdown to the start of the ACCESS Model continues, several digital health experts have issued early concerns about the efficacy of the Model to be able to deliver high-touch, clinician driven chronic care as the payment rates for the Model fell below current billing models.

To Reduce Health Care Waste, CMS Must Focus on How Care is Delivered

An article by Andrew M. Ibrahim, an AcademyHealth Board Member, argues that reducing health care waste requires focusing less on payment reform and more on how care is delivered in real time. Variation in care delivery leads to unnecessary tests, admissions, and higher costs, even when clinical guidelines are clear. Delivery-level solutions, including AI-powered tools, can help standardize decision-making, improve coordination, and ensure evidence-based care is applied consistently across settings.

This perspective shifts the policy conversation. Efforts to reduce Medicare and Medicaid spending often rely on audits, reporting, or payment changes, but these approaches do not address what happens at the bedside. Focusing on real-time care delivery creates a path to reduce waste without restricting access or adding administrative burden, while also improving outcomes and consistency, especially in rural and underserved areas.

For researchers, the focus is moving from generating evidence to ensuring it is used in practice. There is a growing opportunity to study care variation, evaluate how AI and delivery-level tools impact decision-making and outcomes, and produce more actionable, implementation-focused research. This also reinforces the need to connect research to real-world workflows and assess how these solutions can reduce disparities and improve access across different populations.

New Episode: Aaron Carroll on Why Work Requirements Could Cost More Than They Save

The second episode of AcademyHealth’s video series with Healthcare Triage is now live. President and CEO Dr. Aaron Carroll examines the Medicaid provisions in H.R.1 and explains why the administrative costs tied to work requirements, from state eligibility databases to due process hearings, could far exceed any projected savings. Watch now:

Roundup of Newly-Introduced Bills

· The bipartisan Chronic Care Management Improvement Act would eliminate the 20 percent Medicare coinsurance requirement for chronic care management (CCM) services, which cover non-face-to-face care coordination such as care planning, record sharing, and transitions of care. Backed by several provider and advocacy associations, proponents argue this bill will improve care coordination for beneficiaries with multiple chronic conditions and increase utilization of the CCM code, currently used by only 4 percent of eligible beneficiaries despite evidence of cost savings.

· A physician-legislator introduced the Every Dollar Counts Act, which would require commercial insurers to apply prescription drug purchases made through direct-to-consumer (DTC) platforms toward patients’ deductibles and out-of-pocket maximums to reduce patient financial burden and improve access to medications. This bill applies only to drugs on a health plan’s formulary and does not extend to Medicare or Medicaid. Nonetheless, this bill raises important questions about how insurance benefit design shapes drug channel selection and opportunities to reduce out-of-pocket drug spending for patients.