The new federal Medicaid law, known as the Big Beautiful Bill, fundamentally changes how people keep their coverage, requiring both monthly work reporting and eligibility redeterminations every six months. For Massachusetts, this is a significant shift from longstanding policy—and one the state did not choose. The risk is not only that some individuals will fail to meet new requirements, but that many who remain eligible will lose coverage due to administrative barriers. Documentation burdens, frequent renewal deadlines, and complex reporting rules will push residents off MassHealth, unless the state takes deliberate steps to help people navigate the system. Those most at risk, including people with behavioral health conditions and unstable housing, are also the least able to navigate these requirements on their own, making investment in the behavioral health safety net essential to keeping them covered.
The Federal regulation released on June 3 requires many people with debilitating diagnoses to document their inability to work to qualify for an exemption from the requirement. If the intent was to protect those individuals, the effect is the opposite. People who should qualify could instead face paperwork burdens substantial enough to jeopardize their coverage. States have until January 2027 to stand up new systems, which leaves MassHealth a short runway to protect coverage for hundreds of thousands of residents.
The commonwealth should be most concerned about the populations least able to navigate these new requirements on their own. People living with behavioral health conditions, especially those with unstable housing, are at the top of that list. Protecting their access does not require building new outreach campaigns from scratch; it requires strengthening the relationships that already exist: the providers these patients know, see regularly, and trust.
Vinfen operates the Community Behavioral Health Center (CBHC) in Lowell, one of the 27 in the state that provide outpatient and crisis services. The vast majority of those we serve are MassHealth enrollees, often navigating mental illness, substance use disorders, or both. They may be managing the kind of daily fragility that makes a trip to the pharmacy feel like a logistical challenge. They may have gone weeks without seeing a primary care physician, not out of neglect but because that kind of sustained self-management is precisely what their conditions make difficult. They may have unstable housing and low digital literacy, which are both barriers to completing paperwork. For many of them, their regular visit to a CBHC is their most consistent point of contact with the healthcare system.
Of the roughly 300,000 MassHealth expansion members who will be subject to the new rules, more than 30% live with a behavioral health condition. As part of the commonwealth’s Roadmap for Behavioral Health Reform, the state’s 27 CBHCs provide coordinated care to people with complex behavioral health needs and significant social challenges. As of March 2026, they had collectively served more than 112,000 people since opening, a substantial share of them MassHealth expansion members. This is the safety net already in place to reach the population the new rules put most at risk.
The state has not yet finalized its redetermination strategy. As that strategy takes shape, the infrastructure best positioned to help these patients navigate the process should not be an afterthought. The state has taken an initial step of investing in grassroots organizations and a communication campaign through Health Care For All. That effort should be expanded to include safety net providers including CBHCs and community health centers. The new federal rules will generate a significant and sustained increase in demand for application assistance and right now that capacity is not funded.
The legislature will likely face additional requests for redetermination funding in the months ahead. When that conversation happens, CBHCs should be part of it. We are not a peripheral player in the behavioral health safety net. We are, for a substantial portion of MassHealth’s most vulnerable enrollees, the front line. Placing a dedicated application counselor in each CBHC in Massachusetts would cost a fraction of what the state will spend when people lose coverage and later require crisis care, emergency services, or re-enrollment.
Massachusetts built these centers to be an open door. There is no wrong number, no wrong door, no wrong reason to ask for help. That commitment should extend to helping the people who depend on us keep the health coverage that makes their care possible. Funding CBHCs to do this work is not a new program. It is the completion of one that is already underway.
Jean Yang is president and CEO of Vinfen.
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