09/25/2026
CMS has given states a three-tier model for deciding who is medically frail under the new Medicaid work requirements. States must generally start those requirements by January 1, 2027. That is 98 days from today.
The model, released Sept. 8:
Tier 1: a diagnosis alone confirms the condition significantly impairs the person's ability to meet the requirement.
Tier 2: a diagnosis plus supporting data, such as pharmacy, equipment, or utilization records.
Tier 3: records are unclear or missing, so the case goes to manual review and may need documentation.
For health plans, this is an operations question. CMS lists managed care encounter data and plan care management information among the sources states can use. Members with thin records land in Tier 3. That is where people miss a notice, a document request, or a deadline.
Our take: the frailty call will lean heavily on data plans already hold. Plans that clean up encounter data and reach members early can keep eligible people from losing coverage over paperwork. Plans that wait for state notices will be working Tier 3 cases in January.
Right Skale builds AI for eligibility and enrollment operations: organizing member data, flagging who needs follow-up, and supporting outreach until the loop is closed.
Where will your team feel the pressure first: data sharing with the state, member outreach, or documentation follow-through?
Source: CMS guidance (Sept. 8, 2026), summarized by State Health and Value Strategies (Sept. 11, 2026).
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