1115 Waiver Amendments – May 2025 Update: Open Comment Periods

Proposed Medicaid 1115 Waiver Amendments for Kentucky, Georgia, South Dakota, Iowa, and Utah.

Kentucky

Kentucky’s proposed 1115 waiver amendments includes automatic referral of Medicaid expansion adults, aged 19-60, who have been enrolled in Medicaid for over 12 months to workforce development resources. The state would provide information about job placement assistance and connect willing participants to services including apprenticeships, career development, education, employment training, and skill-building resources. Participation would not impact benefits or eligibility. Kentucky estimates about 75,000 individuals will be affected by the new requirement.

Proposed exemptions include individuals with verified income, caregivers of children under 18 years old, individuals diagnosed with diagnosed substance use disorders, serious mental illness, chronic diseases, disabilities, pregnant women, foster youth up to age 26, and anyone in a workforce program.

Comments or inquiries should be submitted via email to: KY1115CommEngagement@mslc.com. The state comment period is open through June 12, 2025.

Georgia

Georgia’s proposed 1115 waiver amendments include imposing work requirements on non-elderly adults with incomes up to 100 percent FPL who are not already eligible for Medicaid. Changes to the existing demonstration include:

• Removing monthly reporting requirements. Instead, compliance with the requirement would be checked at application and annual renewal.
• Eliminating monthly premium requirements (not previously implemented).
• Reinstating one month of retroactive coverage for the first month of application.
• Expanding qualifying activities to include caregiving for children under six who are covered by Medicaid and compliance with Georgia’s SNAP Able-Bodied Adults Without Dependents (AWAWD) program.

Comments can be submitted via the Medicaid comment portal for Georgia’s Pathway to Coverage. The federal comment period is open through June 1, 2025.

South Dakota

South Dakota is proposing a new 1115 waiver demonstration, “SDCareerLink.” The demonstration would impose work requirements on Medicaid expansion adults aged 19-64 with incomes up to 138 percent FPL.

Adults subject to the work requirement would have to be employed, enrolled in job training or school, meeting work requirements of another program (i.e. SNAP, TANF, or unemployment insurance), or serving as caregivers. The proposal does not state a minimum number of hours of work to be compliant.

Exemptions include:

• Physically and mentally disabled individuals or individuals unable to work due to a medical reason;
• Pregnant or postpartum women; and
• Individuals residing in an area considered exempt from SNAP’s able-bodied adults without dependents (ABAWDs) requirements which have unemployment 20% or more above the national average. Exempted areas are redetermined in the SNAP program every two years.

Comments may be emailed to MedicaidSPA@state.sd.us. Please include “SDCareerLink Public Comment” in the subject line. Written comments may also be sent to: DIVISION OF MEDICAL SERVICES DEPARTMENT OF SOCIAL SERVICES 11 700 GOVERNORS DRIVE PIERRE, SD 57501-2291. The state comment period is open through June 18, 2025.

Iowa

Iowa’s 1115 proposal is a five-year extension of its current program Iowa Health and Wellness Plan. The state previously applied for a five-year extension in July 2024 and received a temporary six-month extension that started in December 2024. Iowa is requesting to continue all current parts of its waiver which include

• Monthly premiums on most expansion adults with incomes at or above 50 percent FPL;
• A healthy behavior requirement to forgo premium obligations;
• Disenrollment for non-payment of premiums for individuals with incomes over 100 percent FPL;
• Copayments for non-emergent use of the emergency room;
• Waiving the non-emergency medical transportation (NEMT) benefit for almost all expansion adults; and
• Eliminating 90-day retroactive coverage for all non-pregnant adults except certain individuals in nursing facilities.

Comments can be submitted via the Medicaid comment portal for Iowa’s Health and Wellness Plan. The federal comment period is open through June 21, 2025.

Utah

Utah has extended its state comment period for its 1115 waiver amendments. The 1115 waiver proposal includes requirements for non-exempt members to complete four activities: register for work, complete employment training assessments, finish relevant job training modules, and apply to at least 48 potential employers within a three-month period. Non-compliant members would face a three-month eligibility suspension and potentially loss of eligibility until the end of their eligibility period.

The state proposes fifteen exemption categories, including

• adults over 60,
• pregnant individuals or within 12 months postpartum,
• caregivers of children under 6 years old,
• those working at least 30 hours weekly,
• individuals enrolled at least half time in any school or vocational training or apprenticeship program,
• individuals identified as physically or mentally unable to meet the requirement,
• individuals complying with SNAP work requirements, and
• justice-involved individuals in the first six months after release.

The state comment period is open through June 2, 2025. Comments can be submitted via the Utah comment portal, email at Medicaid1115waiver@utah.gov, or physical mail to

Utah Department of Health
Medicaid and Health Financing
PO Box 143106
Salt Lake City, UT 84114-3106
Attn: Laura Belgique

Learn more

For more information, reach out to Wesley at publicpolicy@familyvoices.org.