Navigating the New Medicaid Work Requirements
Categories: Living with Brain Injury
The passage of the new federal work and community engagement requirements for Medicaid (often just referred to as Medicaid work requirements) has made an already complex program even more challenging. This may especially be true for people living with disabilities (including those living with brain injury) and their loved ones. While we don’t know how work requirements will affect each state, the Brain Injury Association of America (BIAA) is committed to keeping you informed and helping you navigate the new work requirements as more information becomes available.
Here is what we know so far
Verification requirements include 80 hours of work activities per month.
Beginning January 1, 2027, the 40 states and Washington, D.C. that expanded Medicaid as part of the Affordable Care Act (ACA), must verify at application and at renewal that Medicaid recipients meet work requirements (80 hours of work activities per month) or exemption criteria. Examples of work activities may include employment, schooling (at least part-time), volunteering or community service, a job training program, providing caregiver activities for adults living with disabilities or a child aged 13 and under, or a combination of one or more of these activities.
Exemptions from work requirements are possible.
Living with a disability or being a full-time caregiver for an adult living with disabilities or for a child aged 13 years and under should exempt individuals from work requirements. How this will be implemented by each state is still unclear.
Lessons learned from Arkansas’s Medicaid work requirement program found that some people living with disabilities (or serious or complex medical conditions) may be subject to the requirements, as they don’t meet the criteria to receive Supplemental Security Income (SSI) but qualify for Medicaid through the ACA expansion. People living with disabilities may also face difficulties navigating the process to qualify for an exemption.
Federal protocols are still being developed.
The federal government has yet to release implementation protocols to states.
Many will likely lose insurance.
No data is currently available on how the work requirements may or may not affect people living with brain injury and their caregivers. However, researchers estimate that Medicaid work requirements will likely lead to an overall increase in the number of people without health insurance.
Getting documentation in place is key.
Ideally, people will have access to their complete medical records from at least the last 12 months (including clinical or diagnostic tests of cognitive or other disabilities, treatment notes, and documentation of the severity and expected duration of a disability). However, at a minimum, encouraging people to get a letter from a doctor documenting their disabilities or challenges is a good start to help them get or keep their Medicaid coverage.
Each state will be different.
Each state will set and administer work requirements and develop its own verification processes for its state Medicaid program.
Helpful links
The Kaiser Family Foundation has posted helpful information on this new law: