March 13, 2026: National Advocacy Update

| 9 Min Read

New AMA comments, issue brief focus on Medicaid community engagement (work) requirements

As part of its commitment to protect patient access to care as the One Big Beautiful Bill Act (OBBBA) (PDF) is implemented, the AMA continues to engage with CMS, support state and specialty medical associations, and develop advocacy resources for AMA members. 

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As states prepare for Medicaid changes that begin on Jan. 1, 2027, the AMA sent a letter (PDF) to CMS on the OBBBA provision requiring certain individuals to satisfy community engagement (work) requirements (PDF) as a condition of enrolling in or maintaining Medicaid coverage. In the letter, the AMA recommended actions that CMS can take to ensure that states build processes enabling patients to successfully navigate the new requirements without unwarranted coverage disruptions for eligible enrollees. In particular, the AMA asked CMS to work with states to ensure clear and robust processes to appropriately exempt individuals from these requirements, including people who are medically frail. Since the Medicaid expansion population has a high prevalence of chronic conditions, it is critical that the medical frailty and other exemptions are implemented in a manner that is not overly burdensome on either patients or physicians. Since sending the letter, the AMA has been in touch with senior CMS officials to establish a dialogue on the issues raised in the correspondence.  

A new AMA issue brief (PDF) on Medicaid community engagement (i.e., work) requirements and the medical frailty exemption outlines key implementation choices facing states and the implications for patients and physicians. The brief also identifies advocacy opportunities for medical associations to help ensure those who meet this exemption are protected and the administrative burden on patients is minimized. For updated information on OBBBA implementation, visit ama-assn.org/OB3

In comments on marketplace plan changes, the AMA reiterates the importance of maintaining access to coverage that is both affordable and comprehensive

The AMA recently sent a letter (PDF) in response to proposed changes (PDF) to benefits and payments for marketplace plans under the Affordable Care Act (ACA) for the 2027 benefit year. In the letter, the AMA signaled general support for promoting consumer access to and choice of quality affordable coverage options while emphasizing the importance of ensuring all Americans have access to coverage that is not only affordable, but comprehensive. The letter noted that without guardrails, several of the proposed policies intended to boost affordability could threaten access to meaningful coverage, restrict patient access to care, destabilize risk pools and markets, and boost payer profits rather than lower patient out-of-pocket costs. The AMA also noted the importance of consumer transparency, with any plan tradeoffs to keep premiums low such as more restricted provider networks or higher out of pocket costs made clear to consumers when purchasing coverage.  

In the letter, the AMA shared detailed feedback on several specific proposals including counting non-network plans as qualified health plans, expanding access to catastrophic plans, reducing the minimum percentage of in-network essential providers, removing federal time and distance network adequacy standards, and allowing bronze and catastrophic cost sharing to exceed out of pocket limits. The AMA shared concerns about the impacts these changes could have on the broader market and suggested guardrails to help mitigate potential negative impacts. The AMA also expressed support for several proposals to strengthen consumer protections and oversight against broker actions and called for continued monitoring on market impact to ensure continued consumer access to coverage that is both affordable and comprehensive, particularly for Americans living with chronic or high-cost conditions, and those living in rural or underserved geographic areas. The rule would also codify several provisions of the One Big Beautiful Bill Act (OBBBA) pertaining to marketplace plans. For more information on the OBBBA implementation, visit ama-assn.org/OB3.

Federal parity report to Congress shows continued payers’ failures 

Health insurance companies continue to fail to meet basic expectations of federal mental health and substance use disorder parity laws, according to the findings of the 2025 Report to Congress (PDF) from the U.S. Departments of Labor, Health and Human Services, and Treasury. The 2025 report, consistent with previous reports, found that payers and insurers fail to comply with the federal Mental Health Parity and Addiction Equity Act (MHPAEA) in multiple ways, including subjecting enrollees to more restrictive prior authorization for both inpatient and outpatient in-network services, as well as more restrictive concurrent review for outpatient, in-network services. Among the examples provided in the report were plans whose policies or actions caused: 

  • Exclusions of prescription drugs (e.g. methadone) for opioid use disorder 

  • Prior authorization for applied behavior analysis (ABA) therapy more restrictive compared to medical surgical services 

  • Urgent mental health/substance use disorder prior authorization requests taking 36 hours, while medical/surgical urgent prior authorization requests were decided within 30 minutes  

Also similar to previous reports, the 2025 report emphasized that, “During the Reporting Period, [The Centers for Medicare & Medicaid Services (CMS)] observed a continued trend of zero comparative analyses that were sufficient at first submission….In its fourth and fifth years, 2024 and 2025, respectively, of implementing the CAA amendments to MHPAEA, CMS has not seen a marked improvement in the sufficiency of initial NQTL comparative analyses provided by plans and issuers.” 

View an AMA issue brief (PDF) to learn more about actions that states can take.

House Ways and Means Health Subcommittee holds hearing examining rural GME issues

On Feb. 24, the House Ways and Means Health Subcommittee held a hearing entitled “Advancing the Next Generation of America’s Health Care Workforce,” that focused primarily on rural Graduate Medical Education (GME) issues. Since there is a projected shortage of 86,000 physicians over the next decade and physicians are more likely to remain in the communities where they complete medical residency training, both parties highlighted the importance of expanding patient access to care, especially in rural areas. The various causes for the dearth of physicians and policy solutions offered to address the workforce shortage, however, differed across party lines. 

Republicans largely stressed how fewer than 10% of additional residency slots recently allocated by Congress went to rural areas and the desire to increase the supply of American physicians through policies such as the Rural Residency Planning and Development Program. Democrats, however, mostly cited a multitude of recent policy changes including Medicaid reforms, student loan caps, vaccine schedule modifications and H-1B visa filing fee increases, as contributing to physician burnout and exacerbating the ongoing shortage of physicians in the United States. Thankfully, members of both parties touted the importance of passing the AMA-supported H.R. 4731/S. 2439, the Resident Physician Shortage Reduction Act (PDF), legislation to provide 14,000 new Medicare-supported GME slots over 7 years, as one bipartisan solution to the workforce challenges.   

The AMA submitted a detailed statement for the record (PDF) commenting on many of the topics that were explored during the Health Subcommittee hearing. In fact, AMA reiterated its longstanding support for eliminating the current Medicare cap on GME funding via swift passage of the Resident Physician Shortage Reduction Act, as well as the importance of providing additional resources to the Children’s Hospitals GME program and National Health Service Corps. The statement also highlighted a multitude of bills that would help physicians cope with student loan debt and offer new opportunities to train in rural and underserved communities. Furthermore, the statement highlighted the important role that international medical graduates (IMG) can play to help alleviate the ongoing shortage of physicians in the U.S. Both H.R. 5283/S. 2759, the Healthcare Workforce Resilience Act, and H.R. 1585/S. 709, the Conrad State 30 and Physician Access Reauthorization Act, were cited as two ways to leverage IMGs to alleviate the access to care crisis.     

AMA’s written comments, however, also expressed strong opposition to a multitude of bills that seek to address workforce issues by inappropriately expanding the scope of practice for non-physician practitioners. Finally, the statement for the record reiterated AMA’s opposition to H.R. 2314/S. 2715, the Fair Access in Residency (FAIR) Act, which restricts the receipt of limited GME funding by redefining “approved residency programs” to include only residency programs that “affirm” that they “consider for acceptance” applicants from both osteopathic and allopathic medical schools and that they accept both the Comprehensive Osteopathic Medical Licensing Exam of the United States (COMLEX-USA) and the United States Medical Licensing Exam (USMLE). This legislation inappropriately tries to insert the federal government into the construct of medical residency programs, as well as codifies into statute the types of licensure examinations that must be accepted in order to receive GME funding. 

Overall, the AMA pushed for sustained long-term investments to ensure that patients are provided with the best care possible, and that barriers are addressed to resolve the full spectrum of pipeline, educational and workforce issues for physicians. 

HHS U.S. Exchange Visitor Program backlog could further exacerbate physician shortage

Currently, resident physicians from other countries working in the U.S. on J-1 visas are required to return to their home country after their residency has ended for two years before they can return to work in the U.S. However, the HHS U.S. Exchange Visitor Program allows J-1 physicians to remain in the U.S. without having to return to their home country if they agree to perform research in an area of priority or significant interest to HHS or provide care for three years in a mental health or primary care Health Professional Shortage Area. However, to be granted a waiver, HHS must submit its recommendation to approve a waiver request to the Department of State (DoS). DoS must then submit its approval recommendation to the U.S. Citizens and Immigration Service, which then officially can grant a waiver.  

Recently the AMA received communications from physicians noting that there is an administrative hold within HHS that could impact physicians’ projected July 1 start date. Accordingly, on March 10, the AMA contacted (PDF) the U.S. Exchange Visitor Program and urged HHS to utilize emergency batch processing for physicians with July 1 start dates so that these vitally important physicians can remain in the U.S. and continue to care for patients. 

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