Comment on CMS-2026-2047-0002

New Gateways, Inc. appreciates the opportunity to provide comments regarding the Centers for Medicare & Medicaid Services' Interim Final Rule implementing Medicaid work requirements. New Gateways is a Michigan nonprofit organization that provides community-based day services to adults with intellectual and developmental disabilities (I/DD). We support individuals with a wide range of complex medical, behavioral, and cognitive needs, many of whom rely on Medicaid not only for healthcare, but also for the long-term services and supports that allow them to safely participate in their communities, maintain their health, and avoid institutional care. While the intent of encouraging employment is understandable, we are deeply concerned that the administrative requirements associated with this rule will create unintended barriers for many Medicaid beneficiaries who remain fully eligible for coverage but may struggle to navigate complex reporting requirements. The individuals we support often experience significant cognitive impairments, communication challenges, mental health conditions, or physical disabilities that make completing forms, responding to notices, or utilizing online reporting systems extremely difficult without assistance. Even when individuals qualify for exemptions, obtaining physician documentation, understanding eligibility notices, or submitting paperwork within required timeframes can be overwhelming. In our experience, many of the people we serve rely heavily on family members, guardians, case managers, and provider agencies to help them navigate Medicaid requirements. When a guardian is elderly, unavailable, or overwhelmed, or when support coordination resources are stretched thin, important deadlines can easily be missed despite the individual's continued eligibility. Administrative barriers—not eligibility—are often the greatest threat to maintaining coverage. We have seen individuals struggle with: -Understanding government correspondence and required actions. -Limited computer access or digital literacy needed to complete online reporting. -Difficulty obtaining required medical documentation in a timely manner. -Challenges caused by transportation limitations, cognitive disabilities, or communication barriers. -Confusion resulting from changes in Medicaid policies and reporting expectations. Loss of Medicaid coverage, even temporarily, can have significant consequences for individuals with disabilities. Interruptions in healthcare coverage may delay access to physicians, medications, behavioral health services, therapies, medical equipment, and other medically necessary supports. These disruptions can ultimately lead to preventable health crises, emergency room utilization, institutional placement, and higher long-term healthcare costs. As a provider organization, we are also concerned that these additional administrative requirements will increase demands on already limited provider, case management, and care coordination resources. Rather than focusing on direct supports and improving quality of life, staff may be required to spend increasing amounts of time helping individuals understand notices, gather documentation, and resolve coverage issues. We respectfully encourage CMS to carefully consider the impact these requirements will have on individuals with intellectual and developmental disabilities and other vulnerable populations. Any policy intended to improve accountability should avoid creating unnecessary administrative hurdles that result in eligible individuals losing access to essential healthcare coverage. Thank you for considering our comments and for your continued commitment to ensuring that Medicaid remains accessible to the individuals who depend upon it. Submitted by: Lynn Maginity Executive Director New Gateways, Inc. Waterford, Michigan