In January 2018, CMS issued a guidance letter to State Medicaid Directors encouraging states to test new community engagement and work requirements for “able-bodied adults” enrolled in Medicaid.1 As states seek to implement Medicaid work requirements, lawmakers and state healthcare agencies must define the scope of the work requirements and determine which populations should be exempt from these mandates. These challenges are particularly relevant to individuals who use long-term services and supports (LTSS).
States developing new Section 1115 waivers should take care that Medicaid enrollees with functional limitations are not unduly burdened by new community engagement requirements. States should define work exemptions that cover not only individuals who are eligible for Medicaid on the basis of disability, but also individuals in optional and/or Expansion populations who have functional impairments and LTSS needs. States should also ensure that individuals with disabilities have the supports they need to remain independent regardless of eligibility pathway, empowering enrollees without threatening coverage. Finally, exempt individuals who choose to work should receive the LTSS and case management services they need to remain engaged in their communities.
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