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• Direct Validation. While SCDHHS believes the majority of validations can occur through the collection of evidence during the eligibility process and through data-sharing activities with other public programs, some portion of Medicaid members will need to provide documentation of community engagement data to SCDHHS. SCDHHS intends to leverage existing and planned information technology infrastructure to manage this effort and will provide training and resources to eligibility staff to support data collection and validation. Program Participation SCDHHS will limit enrollment in the Palmetto Pathways to Independence program to a maximum of 11,400 members. Individuals will need to demonstrate compliance with the work or community engagement requirements prior to enrollment in the program. Compliance can be demonstrated by meeting a qualifying community engagement activity for at least 80 hours in the month prior to application. Individuals with eligibility in the demonstration will be reviewed for compliance with community engagement requirements at their annual redetermination. An individual will be deemed non- compliant with community engagement if they do not meet community engagement criteria at the time of annual redetermination. An individual who has not met the community engagement criteria at their annual redetermination will be disenrolled from the program. Individuals who do not qualify for any other Medicaid eligibility category will be disenrolled from Medicaid and must reapply and demonstrate compliance with community engagement requirements in order to regain coverage. Individuals who report a change of circumstance during their benefit period that demonstrates non-compliance with the community engagement requirements will be disenrolled from the program. Individuals who do not qualify for any other Medicaid eligibility category will be disenrolled from Medicaid and must reapply and demonstrate compliance with community engagement requirements in order to regain coverage. Before disenrolling an individual, SCDHHS will provide timely and adequate written notice to the individual in advance of disenrollment or reduction of benefits. The notice will also provide full appeal rights as required under 42 C.F.R, Part 431, subpart E. Section 03: Demonstration Waiver Goals South Carolina’s goals for the demonstration are to incentivize employment and close the healthcare coverage gap created by the ACA. The demonstration will support strategies to: • Remove health-related barriers to employment; • Promote member transition to commercial health insurance; and • Support the long-term, fiscal sustainability of the Healthy Connections Medicaid program. SCDHHS intends to demonstrate, through specific hypotheses and evaluations that this approach to supporting employment and easing the ACA coverage gap will improve the well-being of adult participants in the Medicaid program in South Carolina. 8