Who is Disabled Enough? How Medicaid’s New Community Engagement Requirements Could Leave Disabled People Behind
The Centers for Medicare & Medicaid Services (CMS) recently released changes to the Medicaid program that could significantly restrict eligibility for people receiving Medicaid through state expansion rules. Of particular concern to the disability community are the addition of 80 hours a month of community engagement requirements. These requirements place additional burdens of routine reassessment and re-determination on states, and include a vague exemption for people who are “medically frail.” States with Medicaid expansion are expected to implement these changes by January 1, 2027. Disability advocates have expressed widespread concern about these new rules; many disabled people are left anxious about whether they will continue receiving essential healthcare coverage. I am one of those people.
Due to the vague wording of the new Medicaid work requirements, I immediately worried about whether I would qualify for an exemption under the new criteria. As the survivor of an acquired brain injury (ABI), I have come to realize that ABIs are not easily defined. Although I receive Social Security Insurance payments, I still struggle to define my disability status. Disability is not always simple or easily categorized.
After a surgery to remove a brain tumor when I was 14, I was diagnosed with cerebellar mutism. The cerebellum of my brain — the part responsible for fine motor skills and muscle coordination — was not working properly. Even though I was the same person, my physical abilities had changed. I had to relearn how to swallow, eat, move, sit, stand, and walk.
Though the impacts on my life have been significant and have fluctuated throughout the years, my condition remains complicated. A neurologist recently informed me that my ABI likely resulted in permanent cerebellar deficits because I continue to experience difficulties eleven years later.
My experiences have shaped how I understand disability: it is deeply personal and cannot always be captured by a single diagnosis or medical label. Two people can share the same diagnosis and experience entirely different realities. That is why attempts to categorize disabilities through rigid definitions, complicated verification processes, and medical documentation requirements are deeply concerning.
The new Medicaid requirements illustrate this problem. Applicable Medicaid recipients must complete 80 hours of community engagement each month through work, job training, higher education, community service, volunteering, or other approved activities. Details regarding these new regulations can be found in the bill itself.
The questions surrounding these requirements are significant.
First, the legislation provides limited clarity regarding who qualifies for exemptions. These rules directly affect disabled people, yet qualifying and disqualifying disabilities are not clearly defined. How will states determine whose disabilities are “severe enough” to qualify?
Second, these requirements appear to focus primarily on diagnosed disabilities. However, the process of obtaining a diagnosis can take weeks, months, or even years. People experiencing disabling symptoms without a formal diagnosis are still people who need healthcare.
Third, tying eligibility to Social Security benefits creates additional concerns. While receiving SSI does mean that these new work requirements to the Medicaid program will not apply, this does not offer much comfort, as Social Security disability programs have strict eligibility requirements and approval rates remain low. Reducing disability eligibility to paperwork and administrative categories risks ignoring the complex realities of disabled people’s lives.
Even if an individual qualifies for Social Security benefits after providing extensive proof of their condition, they must continue to submit annual documentation that they continue to be disabled. This proves to be a very time-consuming and frustrating task for me, particularly because my disability also greatly affects my writing speed. In the absence of accessible digital submission, filling out the paperwork is a long process, one only made possible through writing in small portions over an extended period. To add to the frustration is the futility of it all; doctors have confirmed that my disability is permanent! To receive an exemption for “medical frailty” under the new rules, both the condition and the impact of the condition on the ability to work will need to be proven every 6 months.
The concern that the new requirements will have a big impact are shared by disability advocates, public health officials, and anti-poverty advocates. Medicaid is a needs-based program that primarily serves people with disabilities and people with low incomes. According to the Centers for Disease Control and Prevention, approximately 1 in 4 U.S. adults has a disability. The Employer Assistance and Resource Network on Disability estimates that 22.2 million working-age adults have disabilities—the same age group affected by these requirements.
Additionally, the Center for American Progress reports that 35.9 million people (10.6%) lived below the poverty line in 2024, while another 88.7 million (26.2%) lived below twice the poverty threshold. Altogether, at least 136.8 million people could be affected by policies impacting low-income Americans.
“It’s just cruelty,” writes Julia Métraux, a reporter at Mother Jones, regarding the burden created by these unnecessary work requirements. Many Medicaid recipients already work full- or part-time jobs. Others are disabled, ill, caregivers, or otherwise qualify for exemptions.
If many people already meet these requirements or qualify for exceptions, why impose additional barriers?
These new hurdles to healthcare create a dangerous situation: people may lose healthcare coverage not because they fail to meet requirements, but because they cannot successfully navigate an overwhelming administrative system.
Unfortunately, cruel policies and damaging actions often find ways to unnecessarily complicate and restrict disabled lives. Such has been shown through the eugenics movements in history, as well as the increasing rates of violence and hate speech leveled at the disability community. Benefit cliffs and marriage penalties structurally enforce inequalities at a systems-level. Cruelty seems to be a recurring theme when it comes to the treatment of disabled people in the world at large. But all hope is not lost.
The Community Engagement Requirements remain open for public comment until July 31, 2026. I encourage readers to submit comments and make their voices heard. Your comment is extremely valuable — public comments can influence what the federal government will allow the states to define as medically frail and what documentation will be needed to prove their exemption.
Healthcare is not a privilege reserved for those who can complete the right paperwork. It is a fundamental necessity, especially for people whose lives depend on it.
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