The Centers for Medicare & Medicaid Services (CMS) released an informational bulletin announcing that, until January 1, 2029, CMS does not anticipate taking enforcement action against states with respect to the deadline for the interested parties advisory group to initially convene and provide recommendations to the Medicaid agency, per 42 CFR 447.203(b)(6). Under 447.203(b)(6)(iv), states are required to convene the interested parties advisory group at least every 2 years, which, based on the effective date of the Ensuring Access to Medicaid Services Final Rule (89 FR 40542, “Access Final Rule”), would be first by July 9, 2026, and next by July 9, 2028. Additionally, under 447.203(b)(6)(v), the Medicaid agency must publish the group’s recommendations within one month of when the interested parties advisory group convenes and provides recommendations to the Medicaid agency. However, CMS does not expect to take enforcement action against states that do not meet these deadlines, provided they convene the group by January 1, 2029. States have the flexibility to convene the group and publish earlier as best suits individual circumstances.
