CMS Approves Work Requirement/Community Engagement & Prior Quarter Coverage Elimination Waivers; Denies 5-Year Eligibility Limit

Last week the Centers for Medicare and Medicaid Services (CMS) approved Arizona’s request to include work requirements and/or community engagement and reporting requirements as a condition of Medicaid enrollment beginning on January 1, 2020.  CMS also approved the request to eliminate prior quarter coverage eligibility effective April 1, 2019.  An accompanying directed waiver request to limit lifetime Medicaid eligibility to 5 years for “able-bodied adults” was denied by CMS. 

CMS’ Letter to Director Snyder is 18 pages long and contains conditions and details- so refer to that letter for the nuts and bolts of what they said.

The work requirement/community engagement Waiver request was filed many months ago and is mandated by Senate Bill 1092 (from 2015) which requires AHCCCS to ask CMS’ permission to implement new eligibility requirements for “able-bodied adults”. 

The program will require some “able-bodied” members between the ages of 19 to 49 years-old to participate in community engagement activities for at least 80 hours per month and report their activities monthly.  Activities can include employment, including self-employment; less than full-time education; job or life skills training; job search activities; and community service.

A member who fails to comply in any given month will be suspended from AHCCCS coverage for 2-months but automatically reinstated after that. Members won't be terminated for failing to comply.

The people exempted from the requirements include:

  • Pregnant women up to the 60th day post-pregnancy

  • Former Arizona foster youth up to age 26

  • Members of federally recognized tribes

  • Designated caretakers of a child under age 18

  • Caregivers who are responsible for the care of an individual with a disability

  • Members determined to have a serious mental illness (SMI)

  • Members who are “medically frail”

  • Members who have an acute medical condition

  • Members who are in active treatment for a substance use disorder

  • Members with a disability recognized under federal law and individuals receiving long term disability benefits

  • Full-time high school, college, or trade school students

  • Survivors of domestic violence

  • People who are homeless

  • People who receive assistance through SNAP, Cash Assistance or Unemployment Insurance or who participate in another AHCCCS-approved work program

Many things need to happen before the January 1, 2020 start date.  We’re hopeful that a robust evaluation component will be included in the program so that adjustments can be made to the policy over time and so that other states can learn from the Arizona experiment.