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New York's Role — Critical Decisions Ahead
The new rule still contains a medical frailty exemption from work requirements, but without proactive action by New York state, eligible Medicaid recipients —including people with IDD — risk losing Medicaid benefits due to paperwork failures.
To ensure continuity of coverage, we are strongly recommending that the state build an automated, data-driven exemption system, ideally tied to OPWDD enrollment.
States can continue to accept self-declarations of medical frailty through December 2027 if reliable documentation is not available. Beginning January 2028, if a self-declaration of medical frailty is accepted at application, enrollees must provide supporting documentation at renewal, typically just six months later.
New York has significant power here, and significant responsibility.
Since states have traditionally been given leeway to decide what constitutes medical frailty, thoughtful statewide policies may be the key to keeping people from falling through administrative cracks and ensuring they retain Medicaid coverage. Some potential policy approaches are outlined below.
New York could use existing data to automatically exempt current Medicaid recipients who have previously met medical frailty requirements, and allow people to self-attest on Medicaid applications. Programs for people with IDD have been identified as potentially able to automate exemptions for all participants. By designing systems that use program enrollment data to confirm exemptions, states could relieve individuals of additional administrative burdens.
OPWDD enrollment could also trigger an automatic exemption. Using verified OPWDD eligibility as proof of IDD status would eliminate the need for people to navigate separate paperwork to confirm their exemption. If the state took this approach, additional strategies would be needed to confirm eligibility for people with IDD and other disabilities who are not enrolled in OPWDD services.
The National Association of Direct Support Professionals (NADSP) issued a statement outlining key risks of this rule, and made a set of seven recommendations, which The Arc New York supports:
- Preserve broad exemptions for people with disabilities, serious health conditions, family caregiving responsibilities, and medically frail conditions.
- Allow simple and accessible ways for people to prove exemptions.
- Permit self-attestation when reliable records are unavailable.
- Use existing state and federal data before requiring people to submit new paperwork.
- Ensure notices are clear, accessible, and available in plain language.
- Prevent eligible people from losing Medicaid because of paperwork mistakes, data delays, computer errors, or inaccessible reporting systems.
- Track and publicly report how many people lose coverage, why they lose coverage, and whether they were likely eligible for an exemption.
Read the NADSP's full statement here.
The Arc New York will continue to engage with the state and OPWDD as they develop processes to comply with the CMS rule. Ensuring that people with IDD and other disabilities continue to receive the supports they are entitled to must be a top priority.
New SNAP Work Requirements Are in Effect
The federal government recently made significant changes to the Supplemental Nutrition Assistance Program (SNAP), which could affect eligibility for New Yorkers who receive these benefits.
Since March, the New York State Office of Temporary and Disability Assistance (OTDA) has been communicating that people who receive SNAP benefits must now be actively employed for 80 hours a month, or participate in job search or education/training for 80 hours per month or volunteer activities for 18 hours per month, or document a qualifying exemption. Most people served by OPWDD will meet at least one exemption.
If people who receive SNAP benefits do not comply, they will only be able to receive SNAP for three months before losing their benefits. The expanded SNAP requirements went into effect on March 1, 2026, and some recipients began losing their benefits in early June.
To help people maintain these essential benefits, OTDA has conducted training and outreach to help social services districts identify people who meet the exemption and ensure they understand the documentation requirements. OTDA is also requiring districts to help clients retain SNAP by assisting with their job search, or offering qualifying activities, such as volunteer opportunities, and more.
Below are some resources from OTDA that help explain the requirements for maintaining SNAP benefits:
For more information about SNAP and the new requirements, please visit the OTDA website.
Read the latest issue of The Arc New York's Connections
Check out “The Long Road to a Budget: Advocacy Makes a Difference” in the latest issue of our Connections Newsletter to read how advocates from across the state made a definitive impact on the outcome of the FY2027 NYS Budget.
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