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Many states are unsure how to implement new Medicaid work requirements, according to a KFF survey

South Dakota Department of Human Services Economic Assistance Application. (Photo by Makenzie Huber/South Dakota Searchlight)

WASHINGTON – State officials say they need more information from the Trump administration before they can fully implement new Medicaid requirements, according to a survey released Thursday by KFF and Georgetown University’s Center for Children and Families.

The Republican “Big Beautiful” law introduced several changes state-federal health program for lower-income people and certain people with disabilities, including those enrolled between the ages of 19 and 65 who work, participate in community service, or participate in an educational program for at least 80 hours per month.

The questionnaire Medicaid program officials from 43 states showed those responsible for implementing the law have questions about how exactly they should determine whether a person meets the new requirements or is exempt.

“In addition to how to define medical disability, states sought additional guidance in a number of areas, including what qualifies as community service, how to calculate part-time school attendance, and what is considered a ‘substantial relationship’ to qualify for a caregiver exemption,” the report said. “They also indicated they needed guidance on what sources could be used to verify, whether self-certification would be allowed if other sources were not available, and how long the verification would take exclusions remains valid.

The law includes several additional exceptions, including for people enrolled in Medicaid who are pregnant, have dependent children, are members of tribal communities or are in the foster care system, and for people released from prison within the last 90 days.

The huge majority of government officials surveyed said they would implement a new work, education or community service requirement early next year.

However, there are a few states that have made progress earlier.

Nebraska plans to start on May 1, Montana on July 1, and Iowa officials have said they will start this year, although they haven’t given a date, KFF reported. The report says Arkansas has scheduled a “soft start” for July but won’t actually remove anyone from Medicaid for failing to meet the new requirements until next year.

Hardship exemptions

The KFF-Georgetown study finds that almost all states will allow hardship waivers to people in counties with higher unemployment; those who have recently experienced a natural disaster; people admitted to hospital or care facility; or those who must travel outside their community for medical care.

The report found that Indiana and Iowa are the only two states that so far do not intend to allow any hardship exceptions to requirements to work, attend community service or participate in an educational program for people enrolled in the Medicaid program.

“Oklahoma does not accept exceptions for residents of high-unemployment or disaster-declared counties, while Missouri does not accept exceptions for residents of high-unemployment counties,” the report said. “New York has no plans to adopt an exception for people traveling outside their community to obtain medical care. Twelve states have not made a decision.”

Lookback periods vary

Thirty-six states will look back at the month in which someone applies for Medicaid to determine whether they are working, participating in community service or participating in an educational program. Indiana and Idaho will look back at the last three months before a person applies to determine whether they meet the new requirements.

Thirty-four states will look back one month during the renewal process, which by law must occur at least every six months.

“Indiana and New Hampshire will review quarterly and at renewal to ensure that registrants are meeting the requirements each month between renewals,” according to the report. “Arkansas will also look back three months for renewal, but does not schedule quarterly inspections. States that had not made a decision at the time of the study included five application states, six renewal states and seven states for more regular inspections.

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