In a previous blog, we reviewed pending and approved 1115 waivers in 11 states. These reviews provide an overview of 1115 waiver applications, including a focus on work requirements, lock-outs, changes in coverage structures, repealing the Medicaid IMD exclusion, and other behavioral health initiatives.  As we continue to monitor these applications, we’ve created a new site to track 115 waivers and will be continuing to update this site with additional state waiver requests and approvals.

On April 30, 2018, Ohio became the latest state to submit an 1115 waiver to include work requirements for certain Medicaid beneficiaries. The waiver application requires individuals in the Group VIII category – those with income level of 0-138% of the federal poverty level (FPL) – to meet the Work and Community Engagement requirement to maintain their Medicaid eligibility. These requirements will closely mirror existing SNAP and Able-Bodied Adults without Dependents (ABAWD) requirements. There are at least fifteen exemptions to the work requirements outlined in the 1115 waiver request.

If the individual is not exempt, they will need to work or participate in a community engagement activity for a minimum of 20 hours per week, or 80 hours averaged monthly. These activities include education and training activities, job search or readiness programs, or the Work Experience Program, which supports beneficiaries in meeting work activity requirements through private or government entities.

Lastly, Ohio is requesting a federal match for supportive services such as transportation to help eligible beneficiaries in meeting the work and community engagement goals. If there is no federal match, the State would consider granting beneficiaries a good cause exemption. To date, Ohio is the only state with a submitted 1115 waiver including work requirements that is pursuing federal match for supportive services to help beneficiaries meet the work requirement.

A complete summary of the Ohio 1115 waiver application is found here.

You can view our complete waiver summary and links to state-by-state summaries by clicking here.

In a previous blog, we reviewed pending and approved 1115 waivers in 8 states. We also highlighted the trends we see in 1115 waivers, such as changes to coverage requirements, a time limit on how long certain beneficiaries can receive Medicaid coverage, lock-outs if an individual fails to pay a premium or meet the work requirement, and drug testing requirements.

It is important to remember that the proposals and concepts we see in 1115 waivers are developed at the state level. And there is typically a lot of state action surrounding 1115 waivers to guide what actually goes into a waiver application.

We have reviewed the state action, legislation, and executive orders as they relate to 1115 waivers, with a specific focus on how states are viewing work requirements, time limits, and lock outs. This summary focuses on states that do not have a pending or approved 1115 waiver including those provisions.

Our analysis shows that 1115 waiver applications are not likely to slow down and trends surrounding Medicaid work requirements are likely to continue. 

Click here to see the analysis on current state activity surrounding Medicaid work requirements.

*Alisa Laufer and Nicole Meyerson contributed to this blog post.