Work and Community Engagement Requirements in Medicaid: State Implementation Requirements and Considerations
Patricia Boozang, Allison Orris, Mindy Lipson, and Deborah Bachrach, Manatt Health
In January 2018, the Centers for Medicare & Medicaid Services (CMS) released a State Medicaid Director Letter providing guidance to states as to the circumstances under which CMS would approve 1115 demonstration waivers making work/community engagement (CE) requirements a condition of Medicaid eligibility. Since then, CMS has approved state work/CE waivers in Arkansas, Indiana, Kentucky, and New Hampshire, and additional states have submitted or are poised to submit similar waivers. Manatt Health has produced a series of charts that outline the legal, policy, financial and operational tasks and issues that states will face in adding a work/CE condition to their Medicaid program.
If you are interested in only one of the charts, they are also available as individual resources:
State Health and Value Strategies also recently hosted a webinar, Explaining the Stewart v. Azar Decision and Implications for States, that provided an overview of the Stewart v. Azar decision and its potential implications for states with approved, pending or planned Medicaid waivers that include work/community engagement requirements.
On March 10, 2025, the Centers for Medicare & Medicaid Services released a proposed regulation that makes several policy and operational changes to the Affordable Care Act Marketplaces and insurance rules. This expert perspective reviews provisions of the proposed rule to assess their impact on State-Based Marketplaces and state insurance regulators.
Congress is considering a variety of federal policy changes that will have significant impacts on the Medicaid program, widely expected to reduce enrollment and federal Medicaid funding to states. A variety of state-level estimates have been released, which can be helpful for states as they consider how various policy proposals might impact their Medicaid programs. This expert perspective highlights state agencies that have estimated and quantified the potential impacts of various proposals on enrollment and spending. SHVS will continue to regularly monitor published estimates from states and update this expert perspective.