1115 Waiver Amendments – April 2025 Update: Open Comment Periods

Learn more about proposed Medicaid 1115 Waiver Amendments for Arizona, Ohio, and Georgia. For more information, reach out to Wesley at publicpolicy@familyvoices.org.

Arizona – Arizona’s proposed 1115 waiver amendments include adding work reporting requirements, time limits to Medicaid coverage, and co-payments for non-emergency uses of ambulance transport or the emergency department (ED). Work reporting requirements would apply to adults aged 19-55 with incomes up to 138% of the federal poverty level (or $3000 per month) for a family of three. The proposed time limits would create a lifetime limit for adults of five years. Proposed co-payments for non-emergency use of the ED and ambulance transport would apply after the third “inappropriate use” of the services, resulting in a $10 copay for each following “inappropriate use.” Exempt populations can be found under Section IV of the proposal.

Comments can be submitted via Medicaid’s public comment page for Arizona. Comment period ends on May 10, 2025.

Arkansas – Arkansas’s proposed 1115 waiver amendments includes creation of the “Pathway to Prosperity” program. Pathway to Prosperity would establish work and community engagement requirements for the Medicaid expansion population. The requirements would apply to all individuals aged 19-64. There are no exemptions to participation and individuals will be evaluated as “on track” or “not on track,” identified through data matching. Those “not on track” will be required to work with a “Success Coach,” rather than meet a specified number of work hours per month. The Success Coach would provide focused care coordination services to support health and economic self-sufficiency.

Comments can be submitted via Medicaid’s public comment page for Arkansas. Comment period ends on May 10, 2025.

Iowa – Iowa’s proposed 1115 waiver amendments include work requirements. To maintain eligibility, non-exempt individuals must meet one of the following requirements:

• Work at least one hundred (100) hours per month or earn wages monthly at least equal to the State minimum wage multiplied by one hundred (100) hours.
• Enrolled in an educational/job skills program.
• Enrolled in and compliant with Iowa’s Temporary Aid to Needy Families (TANF) or Supplemental Nutrition Assistance Program (SNAP) work requirements; or
• Have been exempted from SNAP work requirements.

Exempt populations can be found under “Demonstration Eligibility.” There are no changes to covered benefits, cost sharing arrangements, or delivery system for the program.

Comments can be submitted to QIMP_Public_Comment@hhs.Iowa.gov with subject line “1115 Work Requirement Amendment.” Written comments can also be mailed to Quality/Innovation and Medical Policy Bureau, Department of Health and Human Services, Iowa Medicaid, 321 East 12th St., Des Moines, IA 50319-0114.  Comment period ends on May 15, 2025.