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Many states unsure how to implement new Medicaid work requirements, KFF survey finds

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Economic assistance application for the South Dakota Department of Social Services. (Photo by Makenzie Huber/South Dakota Searchlight)

Economic assistance application for the South Dakota Department of Social Services. (Photo by Makenzie Huber/South Dakota Searchlight)

WASHINGTON — State officials say they need more information from the Trump administration before they can fully implement new requirements for Medicaid, according to a survey released Thursday by KFF and the Georgetown University Center for Children and Families.

Republicans’ “big, beautiful” law made several changes to the state-federal health program for lower income people and some people with disabilities, including that enrollees between the ages of 19 and 65 work, participate in community service, or attend an education program for at least 80 hours a month.

The survey of Medicaid program officials from 43 states showed the people tasked with implementing the law have questions about how exactly they should determine if someone meets the new requirements or is exempt.

“In addition to how to define medical frailty, states wanted additional direction in many areas including what qualifies as community service, how to calculate half-time school attendance, and what is considered a ‘significant relationship’ to qualify for the caregiver exemption,” the report states. “They also indicated they need guidance about what sources can be used for verification, whether self-attestation will be allowed if other sources are not available, and how long verification of exemptions remain valid.”

The law includes several additional carve-outs, including for Medicaid enrollees who are pregnant, have dependent children, are tribal community members or are in the foster care system, and for individuals released from incarceration in the last 90 days, among others.

The vast majority of state officials surveyed said they would implement the new requirement for work, education, or community service at the start of next year.

There are, however, a few states moving forward earlier.

Nebraska plans to begin May 1, Montana on July 1 and Iowa officials said they will begin this year, though they haven’t provided a date, KFF said. Arkansas has planned a “soft launch” for July but won’t actually remove anyone from Medicaid for not meeting the new requirements until next year, according to the report.

Hardship exemptions

The KFF-Georgetown survey says that nearly all states will allow hardship exemptions for people in counties with higher unemployment; those who recently experienced a natural disaster; those who have been admitted to a hospital or nursing facility; or those who need to travel outside their community for medical care.

Indiana and Iowa are the only two states so far that don’t intend to allow any hardship exceptions from the requirement that Medicaid enrollees work, attend community service, or enroll in an education program, the report said.

“Oklahoma is not adopting the exceptions for residents of counties with high unemployment or with a declared natural disaster while Missouri is not adopting the exception for residents of counties with high unemployment,” the report says. “New York is not planning to adopt the exception for individuals traveling outside their community for medical care. Twelve states had not made a decision.”

Look-back periods vary

Thirty-six states will look back one month when someone applies for Medicaid to determine whether they’re working, participating in community service, or enrolled in an education program. Indiana and Idaho will look back at the last three months before the person applied to determine whether they meet the new requirement.

Thirty-four states will look back one month during the renewal process, which must happen at least every six months under the law.

“Indiana and New Hampshire will check quarterly and at renewal to verify that enrollees meet the requirements every month between renewals,” according to the report. “Arkansas will also look back three months at renewal but is not planning quarterly checks. States that had not made a decision at the time of the survey included five states for application, six states for renewal, and seven states for more frequent checks.”