Comment on CMS-2026-2047-0002

I oppose this proposed Medicaid work requirement. The rule does not clearly explain who is exempt from the work requirements, which creates confusion for Medicaid recipients and their families. Many people who rely on Medicaid may not understand whether they are required to comply, potentially putting their health coverage at risk. In my work with individuals and families who depend on Medicaid, I have seen firsthand how difficult it can be for people to navigate complex eligibility and reporting requirements. For example, many caregivers spend nearly all of their time caring for children or adults with significant medical or developmental needs. Even when they may qualify for an exemption, vague rules and unclear communication can lead to confusion, missed paperwork, and unnecessary fear of losing health coverage. There are many situations where people may not know whether they are exempt. A parent may work a job with fluctuating hours and be unsure if they meet the requirement each month. A person with a disability may not know whether their medical condition qualifies for an exemption. Someone receiving treatment for a serious mental health condition may not understand what documentation is needed. Family caregivers often provide around-the-clock care but may not know whether caregiving activities satisfy the requirement. College students, individuals experiencing homelessness, people with limited English proficiency, and those who move frequently may struggle to understand the rules, receive notices, or complete reporting requirements on time. I am also concerned about people who are already working but have difficulty documenting their work activities. Many Medicaid recipients work part-time, seasonal, temporary, or gig jobs. They could lose coverage not because they failed to meet the requirement, but because they misunderstood a reporting rule, submitted paperwork incorrectly, or missed a deadline. This creates unnecessary administrative barriers between people and their health care. This proposal is also problematic for states that will be responsible for implementing and enforcing these requirements. The guidance appears vague and leaves too much room for inconsistent interpretation and administration across states. State agencies will be required to devote substantial resources to determining compliance, tracking exemptions, answering beneficiary questions, and processing appeals, all while trying to ensure eligible individuals do not lose coverage due to administrative errors. Medicaid exists to provide access to health care for people who need it. Policies that create confusion, additional administrative burdens, and barriers to coverage can result in eligible individuals losing access to essential health services. CMS should provide much clearer guidance on exemptions and carefully consider the impact these requirements will have on beneficiaries, caregivers, and state agencies before moving forward.