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State agencies tell Utah commission most federal guidance letters pose implementation burdens but no immediate operational change
Summary
DHHS and related agencies briefed the commission on six federal guidance letters (DEI notification, CMS PDM, SAMHSA guidance, Supporting America's Children and Families Act, and state‑directed payments) and said most are aligned with current practice but may increase reporting and IT demands for compliance.
Salt Lake City — State health and human services officials told the Federalism Commission that several recent federal guidance letters warrant closer review but generally do not require immediate programmatic changes in Utah.
Nathan Brady of the Office of Legislative Research summarized six DHHS letters the commission asked to be reviewed. Tanya Myra, director of the Division of Child and Family Services, said the Family Violence Prevention and Services Act (FVPSA) letter asks recipients to ensure federal funds are not used for unlawful DEIA initiatives and that DHHS currently sees no fiscal or compliance conflict. "At this time we are not seeing that there is any real impact," Myra said.
Office of Substance Use and Mental Health director Eric Tadahara addressed a SAMHSA letter responding to a federal executive order on homelessness and vagrancy. He said Utah's programs already align with the letter's acceptable activities and that no operational changes were required.
Julie Ewing, the newly appointed state Medicaid director, described CMS guidance restarting periodic data matching (PDM) and limits on continuous eligibility waivers. She said periodic data matching will resume and that one state waiver (TAM) covering roughly 6,500 individuals will transition from 12‑month continuous eligibility to a program without that provision, requiring paperwork adjustments but not immediate loss of coverage.
Officials repeatedly flagged increased monitoring and reporting burdens. Ewing noted potential database and AFCARS reporting impacts tied to reauthorization provisions and said DHHS is evaluating how best to implement changes with minimal disruption.
Commissioners emphasized the federalism principle: even when guidance aligns with state priorities, the commission should track federal instructions and preserve the state's flexibility. The commission will expand the agency reporting the legislation envisions to ensure ongoing transparency and to gather written agency assessments for letters not covered at this hearing.
