As reported in the July 3 Washington Update (under “Courts”), a federal court vacated the Department of Health and Human Services (HHS) approval of a Kentucky Medicaid waiver proposal to impose work requirements on Medicaid beneficiaries. The court’s ruling was based on the department’s failure to consider the evidence regarding loss of coverage. On July 18 CMS announced that it would provide another 30-day public comment period for the Kentucky waiver, the deadline for which was August 18. Numerous comments were submitted by health and disability organizations concerned about the potential impact of this waiver. Comments can be viewed here.
Mississippi has also requested a waiver to establish work or community engagement requirements for Medicaid beneficiaries. Under that proposal, those who are employed the required number of hours and get paid minimum wage will then make too much to qualify for Medicaid. (Those who meet non-paying community engagement requirements would still be eligible.) In light of an amendment to the waiver proposal, CMS provided another public comment period, which ended on August 18. Numerous comments were submitted by health and disability organizations concerned about the potential impact of this waiver. Comments can be viewed here.
OPEN FOR COMMENT UNTIL SEPT. 2: New Hampshire
New Hampshire seeks to: 1) provide beneficiaries’ healthcare through the State’s managed care delivery system rather than the current Premium Assistance Program; 2) eliminate retroactive coverage to Medicaid beneficiaries; 3) require documentation of citizenship and residency to determine Medicaid eligibility; and 4) apply an asset test to the Medicaid expansion population.
State-Level Comment Periods
Several states are currently taking comments on their waiver proposals to establish Medicaid work requirements. Alabama is providing a second comment period.
- Alabama Medicaid Workforce Initiative– comments are due August 30. (See second paragraph of Public Notice for submission details.)
- July 31, 2018, revised application
- Oklahoma Soonercare– comments are due September 3.