Comment on CMS-2026-2047-0002

**Public Comment on CMS-2454-IFC: Medicaid Community Engagement Requirement for Certain Individuals** I appreciate the opportunity to comment on the Interim Final Rule implementing Medicaid community engagement requirements. As a nonprofit leader serving Worcester, Massachusetts, I am deeply concerned about the practical impact this rule will have on individuals and families who already face significant barriers to stability. The premise of the rule is that work requirements encourage employment and self-sufficiency. However, the reality in communities like Worcester is that many Medicaid recipients are already working, are actively seeking work, or are serving as caregivers while navigating unstable housing, transportation challenges, untreated behavioral health conditions, or inconsistent employment. The greatest barrier is often not a lack of willingness to work—it is the administrative burden of proving eligibility. Research from previous state demonstrations showed that work requirements did not significantly increase employment but did result in eligible individuals losing health coverage because of reporting requirements, paperwork errors, and confusion about compliance. Losing access to preventive care, medications, behavioral health treatment, and primary care makes it more—not less—difficult for people to enter or remain in the workforce. This concern is especially acute in Worcester. Our community continues to face workforce shortages in health care, behavioral health, human services, and skilled trades while simultaneously confronting growing rates of chronic illness, mental health needs, substance use disorders, and housing instability. Health coverage is a critical support that enables people to address these challenges and participate in the workforce. Removing coverage from otherwise eligible individuals because they fail to navigate complex reporting systems undermines both public health and workforce participation. The administrative costs associated with implementing and enforcing these requirements also deserve careful consideration. Resources devoted to verification, notices, appeals, and compliance monitoring are resources that could instead be invested in employment supports, workforce development, care coordination, transportation assistance, and behavioral health services—interventions with a stronger evidence base for improving long-term employment outcomes. From my experience working with individuals returning from incarceration and those at high risk of violence, consistent access to health care is often one of the foundational elements that allows people to stabilize their lives. Mental health treatment, substance use recovery, medication management, and primary care are not rewards for employment; they are often prerequisites for obtaining and maintaining employment. If the objective is greater workforce participation, policy should reduce barriers rather than create new administrative hurdles. Investments in job training, child care, transportation, education, and integrated health services are more likely to achieve the stated goals without increasing the number of uninsured residents. I respectfully urge CMS to reconsider the implementation of these requirements or, at a minimum, adopt the broadest possible exemptions, streamlined verification processes, and safeguards to ensure that eligible individuals do not lose health coverage because of procedural barriers rather than true ineligibility. Access to health care strengthens communities, supports employment, and reduces long-term public costs. Policies should reinforce these goals rather than inadvertently undermine them. Thank you for considering these comments.