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CMS Approves Medicaid Work Requirements in Arizona

The Centers for Medicare & Medicaid Services (CMS) has approved an amendment to Arizona’s Section 1115 Medicaid demonstration waiver that allows the state to make work requirements a condition of enrollment for certain beneficiaries.

Arizona’s waiver requires beneficiaries ages 19 to 49 who are eligible through Medicaid expansion to work or participate in other community engagement activities for at least 80 hours a month. Failure to comply or report compliance will result in loss of coverage, following a three-month grace period.

Arizona joins seven other states to receive approval for Medicaid work requirements: ArkansasIndianaKentuckyNew HampshireWisconsin, Maine, and Michigan.

The waiver exempts certain individuals who are considered particularly vulnerable or whose circumstances make it more difficult to fulfill requirements, including:

  • pregnant women and women up to two months post-pregnancy;
  • former foster youth up to age 26;
  • beneficiaries with serious mental illness;
  • beneficiaries receiving temporary or permanent long-term disability benefits;
  • beneficiaries who are medically frail;
  • beneficiaries who are in active treatment for a substance use disorder;
  • full-time students;
  • victims of domestic violence;
  • beneficiaries who are homeless;
  • designated caretakers of a child younger than 18;
  • caregivers responsible for the care of an individual with a disability;
  • beneficiaries with an acute medical condition that would prevent them from complying; and
  • beneficiaries with a disability

The waiver also is the first to exempt all American Indian/Alaska Native beneficiaries who are members of federally recognized tribes.

Arizona may begin implementing its work and community engagement requirements on Jan. 1, 2020.

Contact Senior Director of Policy Erin O’Malley at or 202.585.0127 with questions.


About the Author

Rachel Schwartz is a former policy associate at America's Essential Hospitals.

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