Medicaid Work Requirements: Unemployment & Hardship Exception
Summary of the Medicaid Work Requirement Exception for High Unemployment
This text discusses a new exception to medicaid work requirements based on high unemployment rates in specific counties. Here’s a breakdown of the key points:
1.The new Exception:
* A new law allows states to request an exception to Medicaid work requirements for counties experiencing high unemployment.
* This exception aims to provide hardship exemptions for enrollees in those areas.
2. Secretary’s Discretion & Implementation:
* The Secretary of Health and Human Services (HHS) has notable power in how this exception is implemented. They will decide:
* What data states must submit to qualify.
* How long the exception period will last.
* The submission process for states.
* These decisions will directly impact how many states apply,how many counties qualify,and ultimately,how many people are exempt.
* The Secretary must issue rules by June 1, 2026.
3. Guidance from SNAP Regulations:
* the centers for Medicare & Medicaid Services (CMS) is highly likely to look to existing Supplemental nutrition assistance Program (SNAP) regulations for guidance.
* SNAP already has waiver processes for work requirements based on unemployment.
* SNAP regulations allow for readily approvable waivers using 12-month average unemployment rates and specify data standards (BLS data).
* CMS could choose to follow SNAP closely or allow for more/less flexibility.
4. Potential Impact – County & enrollee Numbers (based on KFF analysis):
* Using a strict 12-month average unemployment rate: 158 counties in expansion states qualify, perhaps exempting 1.4 million enrollees (7% of counties and enrollees).
* Using a more flexible “any month” unemployment rate: 386 counties in 34 expansion states qualify, potentially exempting 4.6 million enrollees (17% of counties and 23% of enrollees).
* Significant Demographic Note: While most qualifying counties are rural, the majority of enrollees who could benefit live in urban areas.
5. State Choice & Current Trends:
* States can choose whether or not to apply for this exception.
* 18 states currently do not have SNAP work requirement waivers, suggesting some may be less likely to pursue the Medicaid exception as well.
In essence, the success of this exception hinges on the Secretary’s decisions and the willingness of states to utilize it. The potential impact on enrollment is significant, but varies depending on the criteria used to define “high unemployment.”