Incapacitated? Excuse Me.

One word in Michigan's food assistance policy raises a much bigger question about disability, dignity, and the language of public services.

Incapacitated.

That's the word that stopped me in my tracks while reading Michigan's Supplemental Nutrition Assistance Program (SNAP) work-requirements guidance. Not disabled. Not a person requiring assistance or supervision. Not an individual with substantial support needs. Incapacitated.

There it was, on the Michigan Department of Health and Human Services (MDHHS) website, among the circumstances that may exempt someone from SNAP work requirements:

"Care for an incapacitated person or a child under age 6 (they do not have to live with you)."

… Incapacitated?

As the parent of a child with “substantial support needs,” I spend a considerable amount of time navigating systems designed, at least in theory, to support people with disabilities and their families. I understand that eligibility policies need definitions. I understand that government agencies must distinguish between different circumstances when determining who qualifies for assistance. But I also understand that disability, dependence on caregiving, and incapacity are not interchangeable concepts. And language matters.

Where does this word come from?

Michigan didn't invent it. The term appears in federal SNAP regulations, specifically 7 CFR § 273.7(b)(1)(iv), which exempts a parent or household member responsible for caring for a dependent child under six or “an incapacitated person” from certain work requirements. Michigan carries that terminology into its public-facing SNAP materials. It also appears in the state's online work-requirements guidance and in an October 30, 2026, MDHHS announcement about changes to SNAP work requirements.

These documents serve a practical purpose. They explain when people receiving food assistance may be required to work or participate in approved activities, and when they may qualify for an exemption. That information is important, particularly as work requirements expand.

But consider what happens when a parent or caregiver encounters the word “incapacitated.”

What does it mean?

Does it mean someone who cannot communicate verbally? Someone who needs supervision for safety? Someone who requires assistance with daily activities? Someone whose disability prevents them from living independently?

And who decides?

Those questions aren't merely semantic. A person trying to understand whether an exemption applies to their family may need to interpret that terminology to make decisions about their benefits. The word creates work for the reader.

Michigan already uses different language

Here's where it gets interesting.

Michigan's own Healthy Michigan Plan guidance, addressing Medicaid work requirements scheduled to begin in 2027, identifies an exemption for:

"A caregiver of a person(s) with a disability (someone who needs help with daily activities)."

It's a different program with different eligibility rules, so the two descriptions aren't legally interchangeable. But the contrast is striking. One explanation relies on the broad, antiquated-sounding label incapacitated. The other describes disability alongside a more concrete explanation of support needs. The second gives readers considerably more information about the kind of caregiving the policy is addressing.

Michigan has demonstrated that government guidance can use more specific, person-centered language.

Why isn't that approach consistent?

The problem isn't just one word

I spent more than a decade working in creative operations, with an earlier background in design and consulting. I'm now pursuing a Master of Public Health. One of the questions that increasingly occupies my attention is how institutional systems shape people's access to opportunities, resources, and services.

And one issue keeps surfacing: the extraordinary amount of work institutions transfer to the people trying to use them.

Consider what it takes to navigate public benefits.

You must understand which programs apply to you. Interpret eligibility criteria. Learn unfamiliar terminology. Determine which exemptions might apply. Locate supporting documentation. Reconcile information that may differ across websites, forms, and agency correspondence.

Then you must somehow know whether you've understood everything correctly.

AND if you don’t say all the magic words in perfect order calling any support line, you don’t know if you’ve been misinformed, gaslight, had the rug pulled out, or just need to play some phone call roulette and try again the next business day.

For families navigating disability-related services, this work is exceptionally demanding because eligibility categories may not reflect the complexity of someone's actual support needs. And the consequences of misunderstanding a requirement can be significant.

Cognitive accessibility is already an established consideration in digital design.

The World Wide Web Consortium's Web Content Accessibility Guidelines (WCAG), now at version 2.2, include requirements addressing comprehension, navigation, predictability, and error prevention.

The W3C has also developed supplemental guidance specifically for people with cognitive and learning disabilities. Its recommendations include using familiar terminology, presenting information clearly, reducing demands on memory, and helping people understand complex processes.

These principles are particularly relevant to public benefits systems, where misunderstanding a requirement can have serious consequences.

The standards primarily address digital content. How consistently these principles extend to printed notices, policy documents, and other government communications is a separate question worth examining.

But the underlying issue is the same:

Can people understand what a system is asking of them without having to do unnecessary interpretive work?

And if we already recognize cognitive accessibility as an important part of digital design, why wouldn't we apply that same scrutiny to the language used in public policy?

Can someone understand what the government is asking of them?

Can they find the information they need?

Can they interpret it without having to become an expert in administrative law?

Can they confidently determine what applies to their circumstances?

And why does so much of that responsibility fall on the individual?

When the system creates the confusion, who does the work?

This is where I think the conversation needs to move beyond whether incapacitated is an offensive word.

It may be a term embedded in federal regulations. Michigan may be legally required to preserve it in certain contexts.

But that doesn't necessarily mean it must appear without explanation in every public-facing document.

Government agencies routinely translate complex rules into plain-language guidance. That's the entire purpose of creating materials for the public rather than handing everyone a copy of the Code of Federal Regulations. The question is whether those explanations are designed around the people who must understand them. And whether the government takes responsibility for making that understanding possible.

When a system creates ambiguity, but the individual must expend time and cognitive effort resolving it, that's not simply an inconvenience.

It's an accessibility problem.

And when access to food, health care, or other essential services depends on navigating that ambiguity, it's a public health concern.

So I wrote to MDHHS

I contacted MDHHS to request a review of the language in its SNAP guidance. My question was straightforward:

Is Michigan required to reproduce the federal terminology in its public-facing materials, or does the department have discretion to use more precise, respectful language while preserving the underlying eligibility criteria?

I also pointed to the alternative terminology Michigan already uses in its Medicaid materials.

This isn't a request to change who qualifies for assistance or to disregard the legal requirements governing SNAP. It's a request to examine how those requirements are communicated. Because a person who needs substantial support is not necessarily incapable. And a person trying to understand a public benefit shouldn't have to decode language that obscures rather than clarifies what the policy means.

A small word, a larger responsibility

There are larger debates to be had about SNAP eligibility, Medicaid work requirements, disability policy, and the administrative burden of accessing public services. But sometimes a single word reveals something important about how a system sees the people it serves.

Incapacitated made me stop reading. The question I'm left with is simple:

What would public policy look like if we gave as much attention to how people experience its language as we give to writing the rules themselves?

And how much unnecessary work could we eliminate if we did?

Sources and further reading

Michigan Department of Health and Human Services

How Does an Able-Bodied Individual Meet the Work Requirements?

October 30, 2026: Federal Work Requirements for Some SNAP Recipients Begin November 1

New Healthy Michigan Plan Work Requirements

Federal regulation

7 CFR § 273.7(b)(1)(iv): SNAP Work Requirement Exemptions

Author's note: This article addresses the terminology used in public-facing benefits guidance. It does not suggest that SNAP and Medicaid caregiving exemptions have identical legal definitions or eligibility criteria.

World Wide Web Consortium (W3C)

Web Content Accessibility Guidelines (WCAG) 2.2 — Current W3C Recommendation covering digital accessibility, including requirements related to comprehension, predictability, navigation, and error prevention.

Making Content Usable for People with Cognitive and Learning Disabilities — Supplemental guidance addressing clear language, cognitive load, memory demands, and accessible processes.

Cognitive Accessibility at W3C — Overview of W3C's work on accessibility for people with cognitive and learning disabilities.

Understanding WCAG 2.2 — Detailed explanations of the accessibility requirements, their purpose, and implementation examples.

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