CMS to Allow States to Implement Medicaid Work Requirements

On Jan. 11, the federal Centers for Medicare and Medicaid Services (CMS) released new guidance to allow states to incorporate work requirements in their Medicaid programs. States pursue changes to Medicaid eligibility through Section 1115 Demonstration Waivers. As outlined in the guidance, CMS requires state proposals to describe strategies to assist individuals in meeting work requirements, comply with disability and civil rights laws, and make modifications for individuals with substance abuse disorders.

Ten states, including Wisconsin, have already submitted demonstration waivers proposing work requirements to CMS. The Department of Health Services (DHS) submitted Wisconsin’s waiver in June. The Wisconsin waiver proposed changes primarily to the BadgerCare childless adult population, including substance abuse screening and drug testing, monthly premiums, healthy behavior incentives, and a 48-month eligibility limit.

While Wisconsin’s waiver has not yet been approved by CMS, it is similar to Kentucky’s waiver that was approved last week. Wisconsin’s and Kentucky’s proposals both require 80 work hours per month and exempt students and individuals with disabilities. Wisconsin’s waiver, however, applies only to childless adults and includes fewer activities that would count toward fulfilling the work requirement. To date, Kentucky is the only state whose waiver has been approved.