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Shelley Starkey

Trump Administration Approves Medicaid Work Requirements in Maine, Michigan

January 3, 2019 | Medicaid | Waivers/SPAs | Comments
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The Centers for Medicare and Medicaid Services (CMS) approved waivers from Michigan and Maine last month that would allow the states to implement requirements for Medicaid enrollees to report work or “community engagement” activities each month or risk losing health coverage. Michigan and Maine join five other states that have had Medicaid work requirement waivers approved, while more than ten others are in the process of requesting similar changes to their Medicaid programs. The National Council stands strongly opposed to any provisions that create barriers to health coverage for individuals with mental health or substance use disorders, including Medicaid work requirements.


Michigan’s work requirements, which are set to take effect January 1, 2020, would require adults between the ages of 19 and 62 who do not meet certain exemptions to report at least 80 hours per month of qualified community engagement activities, such as work, job training, or volunteer activities to maintain coverage. Although these requirements will only apply to individuals who received coverage under Michigan’s Medicaid expansion, some experts estimate that over 500,000 Michigan residents could be subject to these requirements, and as many as 54,000 of them could lose their coverage. Additionally, individuals in the expansion population may be subject to premiums up to five percent of their income.

In Maine, where Medicaid has not yet been expanded, every resident that does not meet certain exemptions will be required to report 20 hours of community engagement activities per week and will have to pay premiums up to $40 per month depending on income.

Both Maine’s and Michigan’s Medicaid waivers were submitted under Republican leadership, each of whom were replaced by Democratic Governors in the 2018 midterm elections, an element that may stall implementation of work requirements in the states or stop them altogether.


Implementation of work requirements differs from state to state, as do the challenges each state has faced along the way. Kentucky, for example, has had its work requirement waiver overturned by a district court judge, and subsequently reapproved by CMS. Before Kentucky’s waiver goes into effect on April 1, District Court Judge James Boasberg, who was responsible for the ruling that originally paused its implementation, is set to consider CMS’s reapproval. Additionally, Judge Boasberg will consider the agency’s approval of work requirements currently in effect in Arkansas, which has caused nearly 17,000 individuals to be disenrolled from Arkansas’s Medicaid program as of mid-December for failing to meet reporting requirements.

Be sure the read Capitol Connector each week for updates on the status of these harmful work requirements.