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Care Management Committee presses DSS on CMS rule change for HR 1 medical-frailty definition; self-attestation allowed for 2027
Summary
After a June 1 CMS interim final rule, Connecticut Department of Social Services told the Care Management Committee it will use a crosswalked diagnostic-code set but must add an overlay assessing whether conditions significantly impair ability to work; CMS permits self-attestation for calendar year 2027 and a public comment period is open through July 31.
The Connecticut Care Management Committee heard on June 10 that the federal interim final rule (IFR) issued June 1 has changed how states must identify Medicaid members who are "medically frail" under HR 1, and that the Department of Social Services (DSS) is adapting its plan.
"We started with the Michigan alternative benefit plan... and we were really working under the framework that the medical director network...were trying to do," a DSS clinician involved in the code review said, describing an analytic crosswalk of diagnostic codes compiled with Yale Tobin Center support. The DSS presenter said the state has identified a comprehensive set of codes intended to capture people clinicians would consider medically frail.
DSS counsel and staff told the committee the IFR adds a separate requirement: beyond a diagnosis code, states must evaluate whether a condition "significantly impairs" a person's ability to work or comply with community-engagement requirements. "They are allowing self attestation for calendar year 2027," Bill Halsey of DSS said. He and other DSS officials said the state expects further CMS guidance and is assessing how to combine the diagnosis-code approach with any necessary work-impairment assessment and short-term hardship exemptions.
Committee members raised operational and legal concerns. "If you get it wrong, you're out of compliance, which is billions of dollars," Ellen Andrews warned, urging rigorous testing of any automated approach. Another committee member argued the IFR language may exceed the statute: "I think it violates the statute," the member said, and suggested litigation is likely.
DSS said it will pursue all available data-driven approaches first, leveraging Medicaid claims and other information to automate identification where possible, and is preparing communication tools and prescreeners for clients. The agency also said it is evaluating whether to submit formal comments during the IFR's public comment period; DSS noted CMS had signaled the agency will provide more implementation guidance. A DSS official said state staff are considering simplified attestation forms and community-health-worker support for the first year if automated ex parte processes prove infeasible.
The committee pressed DSS for transparency and data for oversight: members asked DSS to share any comments it submits to CMS before filing, to develop an impact dashboard tracking cost and affected populations, and to expand outreach and training for community health workers and providers.
Next steps: the IFR's comment period is open through July 31 (as DSS described to the committee), DSS said it will continue refining the code set and operational plans and will provide an update to the Care Management Committee at forthcoming meetings.
