Continuum of Care (CoC) Documentation Provides Ex Parte Evidence of Medical Frailty for Homeless Individuals with Disabilities

2026

Federal statute says that States shall use ex parte data to verify exclusions or compliance with work and community engagement requirements without obtaining documentation from Medicaid applicants or members. States and counties can and should use ex parte data from local Continuums of Care to identify people in their Continuums who are verified and enrolled in permanent supportive housing, documented eligible for permanent supportive housing, and/or documented as chronically homeless to meet the medical frailty exclusion from work and community requirements.

This recommendation is not seeking a new exclusion from the work and community engagement requirements. Rather we recommend an identified source of ex parte data from the Continuums of Care that States and Counties can use to exclude homeless individuals with disabilities from the work and community engagement requirements because they meet the medical frailty exclusion.