A number of states have requested Section 1115 waiver authority to impose work and community engagement requirements as a condition of Medicaid eligibility. The Centers for Medicare & Medicaid Services (CMS) has granted waivers to three states—Arkansas, Indiana and Kentucky—to adopt work and community engagement requirements and has issued subregulatory guidance indicating the circumstances under which it will approve similar requests.
This issue brief describes the features of the CMS guidance and state proposals, including the populations subject to the requirements, the allowable work and community engagement activities, and the penalties associated with non-compliance. It also describes implementation considerations CMS has requested that states take into account as well as monitoring, evaluation, and process requirements. It concludes by outlining some of the concerns raised regarding the imposition of such requirements.
Publication Type: Issue Briefs