Medicaid Program: Community Engagement Requirement for Certain Individuals

The commenter opposes the proposed Medicaid work requirement, arguing that the rules are too vague and create administrative barriers for vulnerable populations like caregivers, people with disabilities, and gig workers. They express concern that unclear guidance will lead to confusion, missed deadlines, and the potential loss of essential health coverage for eligible individuals.

Lane Independent Living Alliance opposes the proposed rule, arguing that the "medically frail" definition adds unauthorized functional tests that could exclude eligible individuals with disabilities. They request that CMS align the definition with statutory categories, simplify verification processes for those with poorly documented disabilities, and remove the 80-hour threshold for non-resident caregivers.

New Gateways, Inc., a Michigan nonprofit serving individuals with intellectual and developmental disabilities, opposes the Medicaid work requirements due to the administrative barriers they create. They argue that complex reporting requirements may cause eligible individuals to lose coverage, leading to health crises and increased burdens on care providers.

The California Academy of Family Physicians (CAFP) opposes the proposed interim final rule, arguing that the rigid implementation of Medicaid work requirements creates significant administrative burdens for states and clinicians while risking coverage disruptions for vulnerable populations. They request that CMS provide more flexibility regarding medical frailty exclusions, clarify that physicians are not responsible for eligibility determinations, and extend the implementation timeline.

The Health Alliance of Northern California (HANC), a regional association of community health centers, opposes several elements of the proposed interim final rule because they create administrative burdens and potential barriers to care for rural populations. They specifically advocate for population-level exclusions rather than individual-level exemptions, broader definitions for seasonal workers, and expanded protections for family caregivers and medically frail individuals.

Allies for Children opposes the proposed interim final rule, arguing that the current definition of "medical frailty" creates an unfair burden on vulnerable populations and healthcare providers. They urge CMS to revert to a less restrictive definition, allow for self-attestations, and maximize flexibilities to ensure eligible individuals do not lose Medicaid coverage.

A concerned citizen conditionally supports the proposed Medicaid work requirements for able-bodied individuals under 45, provided the final rule includes robust exemptions for people with disabilities. The commenter argues that without these specific protections and clear congressional authorization, the rule may be legally vulnerable and fail to protect vulnerable populations.

Brad Christensen, Administrator of A Gentle Touch Home Care, opposes the proposed administrative requirements for Medicaid recipients. He argues that the new application and review processes will create significant barriers for medically frail clients and impose an unfunded administrative burden on home care providers.

The New York Disability Advocates (NYDA), a coalition of provider associations, opposes the interim final rule because it creates administrative barriers that could lead to coverage loss for people with intellectual and developmental disabilities (I/DD). They argue that the rule's reporting and verification requirements are unworkable for medically frail individuals and urge CMS to rescind the rule to protect vulnerable populations from losing essential services.

The NY Alliance for Inclusion & Innovation, representing a provider association for the intellectual and developmental disabilities (I/DD) sector, opposes the interim final rule regarding Medicaid community engagement requirements. They argue the rule places an undue burden on individuals with disabilities, provides insufficient time for state implementation, and should exempt the I/DD sector entirely from work requirements.