1. Assessing Applicability of the Community Engagement Requirement

As a threshold matter, the State must first confirm whether an applicant or beneficiary is an applicable individual as defined at § 435.551. This means the State must determine whether the applicant or beneficiary is a specified excluded individual as defined at § 435.554 before determining whether they have demonstrated or are deemed to have demonstrated community engagement. Because a specified excluded individual, as described at § 435.554, is not an applicable individual who must demonstrate or be deemed to demonstrate community engagement during the review period, the State determines if someone is a specified excluded individual or an applicable individual at application based on the month of application, as a State does when evaluating other factors of Medicaid eligibility. At renewal, this means the State determines if someone is a specified excluded individual or an applicable individual when processing the renewal. As further described in section II.E. of this IFC, specified excluded individuals are not applicable individuals and are therefore not required to demonstrate community engagement as a condition of eligibility. Thus, the general process for assessing compliance as described in this section would not apply to a specified excluded individual. See section II.H.3.d. “Processing Certain Changes in Circumstance,” at the end of this section for a discussion of how to address an individual who becomes an applicable individual after being a specified excluded individual or when moving from an eligibility group that does not include applicable individuals to the adult group or a section 1115 demonstration that does.