Administration issues letter encouraging Medicaid work requirements

By Katie Spiker, Kermit Kaleba, January 11, 2018

Early today, the U.S. Department of Health and Human Services released a letter to state Medicaid directors encouraging states to consider imposing new work requirements on Medicaid recipients as a condition of eligibility or continued coverage under the program.

As outlined in the guidance letter, states are able to apply for “demonstration” waivers to federal Medicaid requirements that incentive work and community engagement for “non-elderly, non-pregnant adult Medicaid beneficiaries who are eligible for Medicaid on a basis other than disability.” The guidance follows a March 2017 letter to state governors that encouraged submission of waiver requests for a range of purposes, including the imposition of work or community engagement requirements. At least seven states have already submitted waiver requests relating to work requirements under the terms of the March guidance letter; none of these state requests have been approved, but it is expected that a request from Kentucky may be approved as early as this week.

The new guidance provides additional detail on considerations for states in developing and submitting waiver request relating to work. State requests should be intended to promote better mental, physical, and emotional health for Medicaid recipients, and may also have a goal of promoting poverty reduction for individuals and families. States have the flexibility to determine what activities other than employment can count for purposes of eligibility, including community service, caregiving, education, job training, and substance use disorder treatment. The guidance encourages states to consider aligning Medicaid work requirements with state work requirements under the Temporary Assistance for Needy Families (TANF) or Supplemental Nutrition Assistance Program (SNAP), and notes that individuals who are compliant with work requirements under those programs must automatically be considered compliant with Medicaid requirements. States will not be permitted to use Medicaid funds to support employment or other work activities.

National Skills Coalition has long expressed concerns about work requirements under the TANF and SNAP programs, noting that there is little evidence that such requirements are effective at reducing poverty or promoting long-term, stable employment. While the inclusion of education and job training in the list of allowable activities is helpful, NSC cautions that absent sufficient resources and safeguards, expanding work requirements for vulnerable populations is likely to reduce access to critical health services without providing meaningful opportunities for career advancement. NSC will work with our new Welfare to Careers National Advisory panel and national partners to monitor state efforts in response to this guidance, and continue to advocate for more effective – and less potentially harmful – strategies to help low-income individuals transition into family-supporting jobs.