Comment on CMS-2026-2047-0002

Trillium Employment ServicesOpposeIndividual
Summary: An individual expresses concern that the proposed Medicaid community engagement requirements will create administrative barriers and "bottlenecks" for people with disabilities. They argue that the additional reporting requirements may cause eligible individuals to lose vital healthcare coverage due to paperwork challenges rather than actual ineligibility.
I am writing to share my feedback on the proposed Medicaid community engagement requirements. While I fully support policies that promote employment, community participation, and economic self-sufficiency, I am deeply concerned that the proposed rule may unintentionally create significant barriers for people with disabilities and chronic health conditions who rely on Medicaid. The Core Dilemma: Aligning Policy with Independence For decades, federal and state disability policies have championed competitive integrated employment, community inclusion, and greater independence. However, requiring individuals to prove they are "unable to work" just to maintain essential healthcare coverage directly conflicts with these goals. Policies should not force individuals into a box of total inability when many can and want to work, volunteer, or study when given the right support. Additional reporting and verification requirements threaten to create an administrative bottleneck, causing eligible individuals to lose vital coverage due to paperwork challenges rather than actual ineligibility. The Reality on the Ground: A Family's Story To understand the human impact of these administrative hurdles, consider the experience of families navigating the current system. Take, for instance, a young man named Marcus, who has a developmental disability. Marcus has a deep desire to work alongside his neighbors, earn a living, and contribute to his community like anyone else. Like all of us, Marcus and his family face the everyday pressures of inflation trying to afford basic care, food, rent, utilities, a phone, and necessary medications. Despite Marcus's eagerness to find a part-time job that matches his abilities, his family lives in a state of constant frustration. They already spend dozens of hours a month filling out repetitive paperwork just to maintain his current eligibility. They are forced to rely heavily on agencies just to interpret the rules and submit the forms correctly. Adding another layer of complex reporting to prove he is "exempt" from working would overwhelm his family and risk a lapse in healthcare that keeps Marcus stable enough to seek work in the first place. Conclusion and Recommendations The individuals and families affected by these rules are already navigating incredibly complex systems. They do not want a free pass; they simply want to thrive, work, and afford life’s basic necessities without the fear of losing their health insurance due to a paperwork error. I urge policy makers to refine this rule to ensure that definitions and administration procedures for exemptions are seamless, supportive, and aligned with our shared goal of empowering rather than penalizing individuals with disabilities. Thank you for your time, consideration, and dedication to supporting all members of our community.

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