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 11, 2021, President Biden signed the American Rescue Plan Act of 2021 (the ARP), a wide-ranging package of health care and economic measures responding to the coronavirus pandemic. The ARP includes a broad expansion of the Affordable Care Act’s (ACA) main health insurance subsidy, the premium tax credit (PTC), the first major expansion of the health care reform law since its passage. This piece highlights the policymaking considerations that states must account for in light of the PTC expansion and uncertainty about future federal action. A key theme that emerges is that states will benefit from approaches that give them the flexibility to adjust policies year by year as the federal landscape develops.
