Updated October 20, 2026 — Version 2.0. This revision adds a 12-test rule-version and legal-change-readiness gate. It addresses effective-dated legal authorities, original and revised policy and system versions, documented testing, notice and appeal protections, and independent review. It also clarifies the January 1, 2028 self-declaration transition. These are PERM Insights recommended operating controls, not an additional CMS-prescribed checklist. The originally published September 2026 resource and its download address are preserved.
What’s Inside
Medical-frailty exclusions depend on more than identifying a diagnosis. States must connect condition and impairment evidence to an approved methodology, apply controlled automation and manual-review pathways, communicate the actual decision basis, and retain enough historical evidence to reconstruct the result later.
This practical checklist turns that obligation into an operational control standard. It covers condition-list governance, ex parte source inventory, encounter-data quality, evidence sufficiency, exception handling, self-declaration, notices and appeals, annual reverification, vendor accountability, and Shadow PERM testing.
Use it to assess whether each exclusion determination can be explained from source evidence through the final eligibility action—under the policy, code set, system rule, and effective date that applied at the time.
Current through October 20, 2026 | Version 2.0 | National Medicaid focus
Related Research & Reference: Medical Frailty Litigation: What States Should Track Before Changing Their Controls (PI-027).