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CMS Announces Work Requirement Guidance Under Medicaid 1115 Waivers

January 12, 2018—Centers for Medicare and Medicaid Services (CMS) Administrator Seema Verma Jan. 11 announced, “CMS will support state efforts to test incentives that make participation in work or other community engagement a requirement for continued Medicaid eligibility or coverage for certain adult Medicaid beneficiaries”  under 1115 waivers.

Ten states already have submitted proposals that include employment and community engagement initiatives: Arizona, Arkansas, Indiana, Kansas, Kentucky, Maine, New Hampshire, North Carolina, Utah and Wisconsin.

CMS recognizes that non-disabled adults who are eligible for Medicaid will be subject to the work/community engagement requirements. CMS acknowledges that states may want to exempt certain populations; provide and support individuals with disabilities and others who may be unable to meet requirements; and provide a wide range of allowable activities, such as caregiving, community service, and attending school. 

States also must make exemptions for those who are medically frail or who have acute medical conditions “validated by a medical professional” that would prevent them from meeting the requirements. States must comply with the Americans with Disabilities Act, which would require reasonable accommodations for certain individuals.

CMS also discusses the application of this guidance to individuals with opioid addiction or other substance abuse disorders, which may require modification such as counting time spent in medical treatment toward the work requirement. There will be no Federal Medicaid Match for strategies that states use to help beneficiaries meet work/community engagement requirements.


Ivy Baer, J.D., M.P.H.
Senior Director and Regulatory Counsel
Telephone: 202-828-0499


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Jason Kleinman
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