CMS Approves Medicaid Work Requirements in Maine, Michigan

The Centers for Medicare & Medicaid Services (CMS) has approved Section 1115 demonstration waivers in Michigan and Maine, both of which include work and community engagement requirements as a condition of Medicaid eligibility for certain enrollees.

With the Dec. 21 announcement, Maine and Michigan join five other states to receive approval for Medicaid work requirements: Arkansas, Indiana, Kentucky, New Hampshire, and Wisconsin.

Michigan’s Waiver

Michigan’s waiver extends the state’s existing demonstration through 2023. The waiver now requires individuals ages 19 to 62 who are eligible for coverage through the state’s Medicaid expansion to engage in at least 80 hours per month of work or other community engagement activities, such as education, job training, community service, or participation in substance use disorder treatment.

Enrollees who fail to report their community engagement activities for three months in a 12-month period will be subject to disenrollment.

Certain populations are exempt from the work requirements, including:

• pregnant women;
• primary caregivers of a family members under six years old (limited to one caregiver per household);
• caretakers of a dependent with a disability (one caregiver per household);
• caretakers of an incapacitated individual;
• beneficiaries who are medically frail;
• beneficiaries diagnosed with an acute medical condition that would prevent compliance;
• beneficiaries who have been incarcerated in the past six months;
• beneficiaries receiving unemployment benefits from the state;
• beneficiaries under 21 years old who previously were in foster care; and
• full-time students.

The waiver approval includes new conditions of eligibility for individuals with income above 100 percent of the federal poverty level and continues several previously approved demonstration features.

Maine’s Waiver

Unlike most other states implementing similar waivers, Maine’s work requirements will apply to both the existing Medicaid population and those newly eligible through expansion.

Maine’s waiver will require non-elderly, nonpregnant adult beneficiaries, who are eligible on a basis other than disability, to work or participate in other qualifying activities for 80 hours per month. Failure to comply for three months in a 36-month period will result in termination from the program.

Beneficiaries exempt from the requirements include:

• caretakers for an incapacitated individual of any age;
• parents or caretakers of a child under six years old; and
• individuals who are physically or mentally unable to work at least 20 hours per week.

Maine’s waiver also creates new beneficiary requirements, including premiums. CMS also allowed the state to waive retroactive eligibility.