Comment on CMS-2026-2047-0002
Virginia Association of Community Services BoardsOpposeTrade association
Summary: The Virginia Association of Community Services Boards (VACSB) expresses concern that the new Medicaid community engagement requirements will make it harder for eligible individuals to maintain coverage. They argue that these requirements could lead to significant gaps in care for behavioral health and developmental disability services, ultimately increasing pressure on emergency systems and reducing reimbursement for community service providers.
The Virginia Association of Community Services Boards (VACSB) appreciates the opportunity to provide comments on CMS-2454-IFC and the implementation of nationwide Medicaid community engagement requirements, including eligibility, verification, and coverage-related processes.
Virginia’s Community Services Boards (CSBs) are the 40 public organizations that make up the safety net of services for individuals with behavioral health conditions, substance use disorders, and developmental disabilities. Each year, CSBs serve more than 185,000 individuals, many of whom are uninsured or covered by Medicaid.
H.R. 1 made significant changes to the Medicaid program, including additional eligibility redeterminations, cost-sharing, and work and community engagement requirements for individuals in the expansion population.
For CSBs, the concern is practical. Changes that make it harder for eligible individuals to enroll in or maintain Medicaid coverage can affect access to mental health care, substance use disorder treatment, developmental disability services, and crisis supports.
If individuals lose coverage or experience gaps in coverage, the impact could include:
• Delayed care, poorer outcomes, and more costly treatment needs
• Greater pressure on emergency departments, hospitals, jails, state psychiatric facilities, and crisis services
• Increased reliance on state general fund dollars and local safety net resources
• Lost Medicaid reimbursement for CSBs
• Additional administrative burden for individuals, families, providers, CSBs, managed care organizations, and state agencies
A Virginia-specific analysis estimates that 188,000 Virginians could lose Medicaid coverage by 2034 due to the new work and community engagement requirements, underscoring the importance of clear communication, effective data matching, and careful implementation.
Protecting access to Medicaid helps Virginians remain stable in their communities, supports CSBs’ ability to provide essential services, and reduces pressure on more costly systems of care.