Talking Points on Medicaid Work Requirements
Medicaid enrollees are responsible for meeting work requirements starting no later than January 2027. Even though some disabled enrollees will be exempt, every enrollee will be impacted by these reporting requirements and responsible for completing paperwork to retain coverage. The American Association of People with Disabilities (AAPD) has a plain language explainer on what these requirements mean for people with disabilities. As you start to answer questions about what this looks like for people with disabilities in your state, remember these talking points, compiled by Princeton University’s State Health and Value Strategies’ in their language toolkit. Items in italics are direct quotes:
- Staying Covered: To keep your Medicaid coverage, you either have to prove you’re unable to work, or report regular proof of a job, educational program, or community service. These requirements are specific to Medicaid. You may need to complete other reporting to retain access to other programs like SNAP. If you don’t meet regular reporting requirements, you can lose your coverage.
- Medical Exemption: “Some people do not have to report work activities to get or keep Medicaid. You may not have to work or report work if you have a serious health condition, a disability, a serious mental health condition, you need inpatient care, or are in treatment for a problem with drugs or alcohol. You also don’t have to report if you’re caring for a young child or disabled family member, if you were in foster care and are under age 26, or you’re American Indian or Alaska Native. Individuals may be asked to fill out a screener at application and potentially renewal to determine if they are “medically frail”.” (SHVS Toolkit, pg 6)
- Short-Term Exemptions: “Some people do not have to report work activities for a short time if they face a hardship or emergency. This includes a hospital stay, travel for medical care, a natural disaster, or trouble finding work in your community.” (SHVS Toolkit, pg 6)
- Coverage Renewal: You will be asked to renew your Medicaid coverage likely every 6 months, rather than annually. This means, even those who are exempt from work requirements will still need to provide proof of exemption at every renewal period. The renewals are just a routine to stay covered.
- Reporting Requirements: People may need to report their work and community activities when applying for and renewing Medicaid coverage. You will need to share your history of work, volunteering, or school attendance for a period of time leading up to your application submission.
- Meeting Work Requirements: Another way to meet work requirements is by showing that you’ve earned at least $580 per month. Sharing your total earnings is also accepted as an alternative way of proving you met the work requirements. This amount equals 80 hours of work at the federal minimum wage of $7.25 per hour. Various non-work activities also count toward these requirements: unpaid community service or volunteering, attending an educational or training program (vocational or trade programs count), or job skills programs.
Be aware that states will determine how to screen for people with serious health needs that would exempt enrollees from work reporting. Enrollees will need to share diagnostic information about their physical and mental health to qualify for exemptions. People who receive Supplemental Security Income (SSI) should be exempt from reporting under the law. Additionally, people receiving Social Security Disability Insurance (SSDI) or Home and Community-Based Services (HCBS) should also be exempt, depending on how states roll this out. Pay attention to how this requirement is determined in your state as the HR1 requirements are implemented over the coming months. These work reporting requirements are relevant for the 20 million people in the Medicaid expansion states and the District of Columbia only.
People may have the option to automate their Work Requirements reporting by consenting to share income data from their payroll or bank accounts directly. This CMS tool is dubbed “Eligibility Made Easy” or Emmy. This is one way that artificial intelligence tools are being proposed to streamline Medicaid reporting requirements, as outlined by the Bipartisan Policy Center.
People you’re supporting may have questions about their reporting requirements for related programs like the Supplemental Nutrition Assistance Program (SNAP). The Center on Budget and Policy Priorities (CBPP) indicates that as states streamline the reporting for various programs, SNAP may be able to make use of Medicaid reporting to ensure enrollees reduce their paperwork burden. According to the Kaiser Family Foundation Medicaid Work Requirements tracker, 24 states so far have integrated their Medicaid and SNAP eligibility systems to ease enrollment. Read more about what work requirements implementation is looking like so far in California and Nebraska.
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