Ob-Gyn Societies Issue Joint Statement Opposing Medicaid Interim Final Rule

The undersigned medical organizations representing ob-gyns strongly oppose the interim final rule issued by CMS on Wednesday, June 3, which would impose work and community engagement requirements on millions of people who rely on Medicaid for care.

The rule, issued in accordance with H.R. 1 of 2025, goes beyond legislative intent in several ways that will harm both patients and clinicians. Specifically …

• It limits "self-attestation," which will result in greater administrative burden and exacerbate barriers to care for patients and families. Self-attestation allows individuals to report their work status or exemption without additional documentation only when reliable data is not available. Starting in 2028, self-attestation will be eliminated. This provision, besides requiring more onerous paperwork, would be particularly problematic for many uninsured patients who require medical frailty exemptions and have health-related social needs, low health literacy, or lack access to a physician who can document that status
• CMS provides a restrictive definition of "medical frailty" in the rule, which would have a disproportionate impact on patients with serious health conditions, including gynecologic and reproductive cancers. The rule does not provide states with a list of diagnoses that constitute medical frailty, and at the same time, it prohibits states from adding categories of individuals, such as those with cancer, to the medical frailty definition. This makes the application of the medical frailty exemption unclear and prone to inconsistencies that would limit access to care and contribute to worse cancer outcomes and lower survival rates.
• The rule places an increased administrative burden on already overwhelmed clinicians. Under this rule, clinicians would spend more time creating new documentation to attest patients' community engagement requirements or exemptions, and they would have less time available for direct patient care.

On behalf of the patients we serve, the undersigned organizations call on CMS to reverse course on this arbitrary and cruel rule before it negatively impacts the lives of millions of vulnerable patients and families.

American College of Obstetricians & Gynecologists
American Society for Reproductive Medicine
American Urogynecologic Society
Society for Maternal-Fetal Medicine
Society of Family Planning
Society of Gynecologic Oncology