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First, there was the dispute over whether states should expand Medicaid eligibility under the Affordable Care Act. Now it's work requirements.

As of August 2018, the Centers for Medicare & Medicaid Services has approved Medicaid work requirements for Kentucky, Indiana, Arkansas, and New Hampshire. More approvals likely will follow because Arizona, Kansas, Maine, Mississippi, Ohio, Utah, and Wisconsin have work requirement waivers pending before CMS. On June 22, 2018, Michigan Gov. Rick Snyder signed a bill seeking a waiver from CMS that would require Medicaid beneficiaries enrolled in Healthy Michigan to work 80 hours per month.

On June 5, 2018, Arkansas became the first state to implement Medicaid work requirements. Kentucky’s work requirement was scheduled to take effect July 1, but on June 29 a federal judge blocked the requirement.

These work requirements will change the Medicaid landscape and lead to decreased enrollment.

The work requirements target non-elderly, adult beneficiaries who are not pregnant and are on Medicaid for reasons other than disability. Work activities generally include employment, going to school, job skills training, receiving treatment for substance use disorder, or community service.

In general, former foster care youth, pregnant women, primary caregivers of a dependent, medically frail individuals, those diagnosed with acute medical conditions that prevent them from working, and full-time students are excluded from the requirements.


A brief look at the work requirements:

  • Kentucky was the first state to have its Medicaid work requirement approved. Its waiver requires non-exempt beneficiaries ages 19 to 64 to work 80 hours per month.
  • Indiana’s work requirement depends on how long the beneficiary has had Medicaid coverage, ranging from zero to up to 20 hours a week.
  • Arkansas’ waiver requires able-bodied beneficiaries ages 18 to 49 to work 80 hours per month. Those who do not do so for three consecutive months will be locked out of Medicaid for up to nine months.
  • New Hampshire became the fourth state to have a Medicaid work requirement approved. Under New Hampshire's work requirement, beneficiaries ages 19 to 64 must engage in 100 hours of work activity a month.


What’s the big deal?

While requiring able-bodied Medicaid recipients to work may seem like a no-brainer, it’s not as cut-and-dried as that since about 60 percent of Medicaid recipients already are employed full- or part-time in low-income jobs.

In addition, states have different income limits for Medicaid eligibility. States that have not expanded Medicaid eligibility under healthcare reform or under an alternative model may have a hard time getting approval from CMS.

What’s next?

Although CMS is approving work requirements and Arkansas has implemented its requirement, opponents are not giving up and have taken the fight to court.  Since a federal court has blocked Kentucky from implementing its work requirement, expect other states to follow.


Joyce Caruthers is a senior analyst for Decision Resources Group. Follow her on Twitter @JCaruthersDRG.

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