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DSS warns HR1 interim rule narrows medical‑frailty exclusions; 57,000 could need further review
Summary
DSS told the committee that CMS’s June 1 interim final rule narrows the medical‑frailty exclusion for HR1 work requirements, requires 12 months of claims data and allows self‑attestation only in 2027; DSS estimates roughly 57,000 Husky D enrollees may require additional review under a strict medical‑frailty hierarchy.
Peter Abbott, deputy commissioner at DSS, told the committee on June 12 that HR1’s community engagement and work requirement rules will pose operational challenges and that the June 1 interim final rule (IFR) narrows the medical‑frailty exclusion by adding a requirement that a condition 'significantly impair' an individual’s ability to comply with the work/community engagement standard.
Abbott said the department’s baseline Husky D population is about 316,000 and that an updated data review in May identified roughly 206,000 individuals for whom DSS already holds data indicating exemption or compliance; roughly 110,000 remained as a delta needing further verification. Using diagnosis‑code methods developed with clinical review and multi‑state datasets, DSS identified roughly 131,000 individuals who could meet an earlier, broader medical‑frailty definition, but under a hierarchical approach that treated medical frailty as a last‑resort category the remaining population potentially dependent solely on medical‑frailty determinations is about 57,000.
Abbott flagged key IFR operational implications: CMS requires use of the prior 12 months of claims data for determinations; self‑attestation is acceptable during calendar year 2027 but from 2028 states will need verifiable documentation; and good‑faith waivers of start dates are likely to be limited. "This IFR definition is more restrictive than we'd originally considered," Abbott said, noting the department is working with other states and federal partners to interpret the rule.
DSS described an 11‑agency data‑matching initiative (with Yale and other state partners) to identify where state data can support ex‑parte eligibility determinations and reduce burdens on clients. The department also launched an HR1 toolkit and a Medicaid work‑requirements prescreener for enrollees at portal.ct.gov/dss-hrone.
Next steps: DSS plans to continue refining its medical‑frailty algorithm, expand data matches to validate exemptions and share toolkits and prescreeners with the public and community partners in advance of January 1, 2027.
