'Community Engagement Requirements' Will Eliminate Medicaid Benefits for Millions. Here's What You Can Do.

The current administration is about to implement a rule that could kick as many as ten million people off Medicaid: A “community engagement requirement” designed to make it harder to get, and keep, Medicaid coverage. This hastily-implemented rule has huge implications for everyone on Medicaid and is yet another swing at the 61-year-old program, designed to dismantle it altogether. 

The rule applies to people who receive Medicaid through expansion programs, around 18.5 million Americans. While it won’t directly hit medically complex children and their caregivers, it will undermine their access to healthcare, and when they reach adulthood, they could be at risk of losing their Medicaid coverage. We need to fight back, and here’s what you need to know. 

What are “community engagement requirements”?

Also known as “work requirements,” community engagement requirements expect those they define as able-bodied adults to either work a minimum of 80 hours per month; be enrolled at least half-time in school; perform 80 hours of community service; have an income of at least 80 hours a month at federal minimum wage; or a mix of these.

Medicaid recipients will need to prove that they can meet these requirements in initial applications and in every redetermination to confirm they are still eligible for Medicaid. This will make applying for and keeping Medicaid very difficult. 

Does the rule have exemptions for people who might not be able to meet them?

Yes, sort of. The rule provides exceptions for people such as former foster children; parents and guardians of disabled people and children under 13; veterans with total disability; and people who are pregnant or post-partum. It also includes exceptions for people who are “medically frail,” but this term is not well-defined, and there’s a possibility that disabled people could actually be forced to meet these requirements. 

The rule itself states that the Department of Health and Human Services does not think Medicaid should be a “lifelong program.” That implies that they’re hoping to disqualify people or limit their coverage as much as possible. For medically complex and disabled children, that could mean losing Medicaid or not having consistent coverage in adulthood.

What effect will this have on Medicaid?

The rule will add a lot of administrative burden to state and local Medicaid offices, which could create logjams that increase application processing time, a serious issue for people who urgently need Medicaid coverage. The added administrative work will cause the costs of administering Medicaid to balloon, putting significant funding strain on the program, which is already facing close to a trillion dollars in federal funding cuts. Individual states may try to offset these funding shortages with higher contributions and that will in turn disrupt state budgets—this option is also limited for states with tight budgets or deficits.

Because of this, states will be looking for as many ways as possible to reduce Medicaid spending. Those cuts are going to come from “optional” programs that do not have a federal mandate first. That means home and community-based services, especially in light of the administration’s recent memo stating that states do not have an obligation to provide community care, and can instead institutionalize people—this legal opinion does not conform with decades of legislation, rulemaking, and caselaw, and the disability community will be fighting it!

Could this affect healthcare more broadly?

Yes. Medicaid funding is an essential part of the budget for healthcare providers, companies that manage durable medical equipment, and anyone else associated with the medical field. Losing Medicaid patients and funding could force some to scale back services, relocate, or close altogether, especially in low-income communities where funding is already tight. Even if you wouldn’t lose your coverage under the rule or aren’t even on Medicaid, this will make it harder for you to access healthcare overall. 

What can I do?

You can share news about this rule: Many people are not aware it’s happening and that it might affect them and their loved ones in January 2027. You can share more information from advocacy organizations such as the American Association of People with Disabilities, Autistic Self Advocacy Network, and the Center for Budget and Policy Priorities.

You can also leave a comment in the Federal Register, which is where all government agencies have to post rules so members of the public can comment. In your comment, explain how the rule will affect you, people you care about, and access to healthcare. Tell the agency to consider rescinding (taking back) the rule or modifying it to address concerns like yours. Your comment can be just a few sentences about what Medicaid means to you and how difficult it already is to apply for and maintain coverage! Lots of organizations are leaving more formal, technical comments, so you can focus on telling your personal story.