The National Alliance for Direct Support Professionals is deeply concerned that federal implementation of Medicaid work requirements enacted through H.R. 1 could harm people with intellectual and developmental disabilities, families, direct support professionals, and the broader disability community.

Medicaid is the foundation of community living for millions of people with disabilities. It funds Home and Community-Based Services, employment supports, personal care, behavioral supports, transportation, and the direct support that allows people with disabilities to live safely and with dignity in their own homes and communities.

H.R. 1 requires many Medicaid expansion adults to document at least 80 hours per month of work, education, community service, or other qualifying activity. The law includes an exemption for individuals who are medically frail, including people with physical, intellectual, developmental, mental health, substance use, and complex medical conditions. Importantly, the statute does not require a person to prove they are unable to work in order to qualify for the medical frailty exemption.

The NADSP is concerned that CMS guidance could narrow this exemption by tying medical frailty to an “inability to work.” That would create a dangerous catch-22. A person with a disability who works a few hours a week, participates in supported employment, volunteers, or pursues competitive integrated employment could risk losing the Medicaid services that make that participation possible. A person who stops working to prove eligibility could lose income, purpose, and community connection.

This would undermine decades of progress in disability employment. People with intellectual and developmental disabilities should not have to avoid work, job exploration, or supported employment to protect access to Medicaid-funded services. Employment and independence belong together.

We are also concerned that CMS may limit or eliminate self-attestation for medical frailty and family caregiver exemptions. Many states are still developing verification systems, notices, data-matching tools, and eligibility workflows. If self-attestation is eliminated before reliable systems exist, eligible people may lose coverage not because they do not qualify, but because the bureaucracy cannot recognize that they do.

We urge CMS and federal policymakers to preserve the full statutory medical frailty exemption, protect people with disabilities who work or seek work, maintain state flexibility, allow accessible verification methods including self-attestation when needed, and prevent coverage losses caused by paperwork failures, data delays, or confusing reporting requirements.

Direct support professionals know that people with disabilities contribute to their communities in many ways. Their independence should not be measured by an arbitrary 80-hour monthly standard, and their access to Medicaid should not depend on navigating a broken paperwork process.

Medicaid is a lifeline. Work should not become a trap. Disability should never be treated as a paperwork problem.