Tracking Medicaid Work Requirement Proposals

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We here at Georgetown University CCF are closely tracking Medicaid Section 1115 demonstration waiver proposals as states attempt to create new barriers to coverage. There are many troubling proposals pending, but one of the most common is the imposition of a work or community service requirement as a condition of Medicaid coverage. As a reference, below is a list of states that have active work requirement proposals pending.

Many of the proposals share similarities, but no two proposals are exactly alike.

Medicaid Expansion States:

Arkansas –  The Arkansas Works demonstration proposal requires 80 hours of work activities per month from target enrollees. Failure to comply for any three months during the coverage year results in termination and locks the enrollee out of coverage until the beginning of the next coverage year. The federal comment period concluded in August. The proposal is now under CMS review.

Arizona – During the 2015 legislative session, the Arizona state legislature passed SB 1092 which directs the Arizona Health Care Cost Containment System to submit a Section 1115 request to CMS to impose work requirements. The state comment period on the original proposal took place in early 2017, and the proposal is being revised by the state before a possible December submission to CMS.

Indiana – The Healthy Indiana Plan 2.0 application and an amendment to the application were submitted to CMS earlier this year. Both the application and amendment have undergone a federal comment period. The proposal is current under CMS review.

Kentucky – The original Kentucky HEALTH proposal was submitted to CMS in 2016, with an amended proposal submitted in July 2017. The application has undergone the federal comment period; it is under CMS review. Kentucky is expected to be one of the first states in which CMS will approve a work requirement, and this approval is expected to come very soon.

New Hampshire – The federal comment period for the New Hampshire Health Protection Program Premium Assistance proposal closed on December 2. The proposal is currently under CMS review.

Non-expansion States:

Kansas – The KanCare 2.0 waiver includes a 36-month limit of eligibility, even if enrollees are meeting the work requirement. The work requirement would apply to very low-income Section 1931 parents as well as Transitional Medical Assistance households unless they fall under an exemption category. The state comment period ended on November 30; the state expects to submit the proposal to CMS by December 31.

Mississippi – The work requirement is again aimed at Section 1931 parents and Transitional Medical Assistance recipients. The state comment period ended on November 30. Mississippi Division of Medicaid plans to submit the proposal to CMS in December.

Maine – The state submitted this proposal to CMS back in August, and it is now under CMS review. In the interim, Medicaid expansion passed in Maine as part of a ballot initiative.  

North Carolina – The North Carolina Medicaid Reform Demonstration proposal is an amended version of the state’s managed care proposal. The federal comment period opened on December 5 and ends on January 5, 2018. The proposal notes that pending legislation to expand Medicaid includes premiums and a work requirement and asks for waivers to implement them. No comment was taken at the state level on these provisions.

Wisconsin – The state submitted this proposal in June; it is currently under CMS review. In addition to the work requirement, there are several other barriers to coverage such as drug testing and a 48-month time limit.


For more information on Medicaid Section 1115 demonstration waivers and work requirements, see the resources below:

For those waiver proposals that have been submitted to CMS, you can see comments submitted by Georgetown University CCF, the Center on Budget and Policy Priorities and others.

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