Work Requirements Can Be Used as a Basis for Medicaid Eligibility

New guidance from the Centers for Medicare and Medicaid Services (CMS) allows work requirements to be used as a basis for eligibility for certain Medicaid beneficiaries through 1115 waivers. Those who can be subject to work requirements include nonelderly, nonpregnant adult Medicaid beneficiaries who are eligible for Medicaid on a basis other than disability. The guidance also outlines that exemptions/protections from work requirements must be made for individuals who are medically frail or have substance abuse disorders. And, it says states should outline how they would support beneficiaries with limited employment opportunities such as in economically depressed areas, rural areas, with transportation limitations, etc.

Currently, nine states (Arizona, Arkansas, Indiana, Kansas, Maine, Mississippi, New Hampshire, Utah and Wisconsin) have applications pending asking for permission to include some type of work requirements. Kentucky recently had its waiver, which included work requirements, approved by CMS. The Kaiser Family Foundation found approximately 40 percent of non-SSI Medicaid adults are not working, and these individuals are most likely to be affected by this policy. The remaining 60 percent of non-SSI Medicaid adults who either work part time or full time would, presumably, meet any work requirement policy.