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Medicaid Work Requirement Would Not Affect Majority in Colorado's Program

Medicaid. Work requirements.

Two things that have never been combined. Until now.

This morning, the federal Centers for Medicare & Medicaid Services (CMS) invited state Medicaid directors to institute work requirements for certain able-bodied adults as a condition of Medicaid coverage.

Under Colorado’s current Democratic governor, work requirements in Health First Colorado, the state’s Medicaid program, are unlikely. Most Health First Colorado enrollees who can work are employed, and children, seniors, pregnant adults and adults with disabilities would not be subject to any proposed work requirement.

It is difficult to estimate the number of people who could be affected in Colorado if a future governor wanted to set up work requirements. An estimated 75 percent of adults in Health First Colorado already work, and many of the remaining 25 percent are likely students, caregivers, unable to work, already looking for work, or fitting one of the many other exemption criteria.

CMS’s new guidance is a drastic departure from more than 50 years of Medicaid policy. Coverage has never been dependent on a recipient’s work status. That doesn’t mean states haven’t tried, though. As many as a dozen states have requested or are considering asking permission to implement work requirements in their Medicaid programs.

Kentucky, in its September 2016 waiver application, proposed work requirements for adults who are not “medically frail” as a condition of participation in Medicaid. Kentucky’s definition of work includes traditional employment, volunteer work, caregiving, training or searching for a job.

Kentucky officials project Medicaid enrollment will shrink over time because more participants will transition to commercial coverage.

Critics disagree. They are concerned about the ambiguous definition of “medically frail” and the potential increased burdens on low-income families. The red tape of imposing a work requirement, they say, could add new costs, discourage enrollment, and make it more likely that people would inadvertently lose their coverage for administrative reasons. Undoubtedly, similar concerns will be raised with applications from other states.

As of this morning, Kentucky’s application had not yet been approved. But Medicaid programs around the country will be watching closely to see if CMS allows it to move forward with work requirements and other proposed changes. So, too, will CHI.

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