Longtime Washington denizens recognize that Congress and the president enacting a bill into law does not end the policymaking process — far from it. Enactment stands not as the end of the process, nor even the beginning of the end, but rather (to borrow from Churchill) the end of the beginning. Federal agencies must then translate statutory language into federal regulation.
To that end, the Centers for Medicare and Medicaid Services (CMS) released its rule implementing Medicaid work requirements from last year’s budget reconciliation measure on June 1, as required by that law. Because the work requirements take effect on Jan. 1, and state Medicaid programs need clear “rules of the road” before that date, Congress specified that the interim final rule will take effect before CMS can respond to public comments. However, the public can still submit comments between now and July 31, and CMS will consider those comments when drafting the final regulation.