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

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 the Georgetown University Center for Children and Families.

The Republicans’ “big, beautiful” law brought several changes the federal health program for lower-income people and some people with disabilities, including requiring participants between the ages of 19 and 65 to work, perform community service, or participate in an educational program for at least 80 hours per month.

The Opinion poll from Medicaid program officials from 43 states showed that those tasked with implementing the law have questions about how exactly they should determine whether someone meets or is exempt from the new requirements.

“In addition to defining medical frailty, states wanted additional guidance in many areas, including what counts as community service, how half-time school attendance is calculated, and what counts as a ‘significant relationship’ to qualify for the caregiver exemption,” the report said. “They also indicated that they need guidance on which sources can be used for verification, whether self-certification is permitted when other sources are not available, and how long verification of exemptions remains valid.”

The Law includes several additional exemptions, including for Medicaid enrollees who are pregnant, have dependent children, are members of a tribal community, or are in the foster care system, as well as those who have been released from custody in the past 90 days.

The extensive majority of state officials surveyed said they would implement the new work, education or community service requirements early next year.

However, there are some states that are moving forward sooner.

Nebraska plans to start on May 1, Montana on July 1, and Iowa officials said they would start this year, although they did not provide a date, KFF said. According to the report, Arkansas has planned a “soft start” for July but will not exclude anyone from Medicaid who does not meet the new requirements until next year.

Hardship exemptions

The KFF-Georgetown survey says almost all states will allow hardship exemptions for people in counties with higher unemployment; those who have recently experienced a natural disaster; those admitted to a hospital or nursing facility; or those who need to travel outside their community for medical care.

Indiana and Iowa are the only two states so far that will not allow hardship exemptions to the requirement that Medicaid participants work, do community service or enroll in an educational program, the report said.

“Oklahoma is not adopting the exemptions for residents of counties with high unemployment or a declared natural disaster, while Missouri is not adopting the exemptions for residents of counties with high unemployment,” the report said. “New York does not plan to implement the exemption for people traveling outside their community for medical care. Twelve states had not made a decision.”

The lookback periods vary

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

Thirty-four states will spend a month looking back on the renewal process, which by law must occur at least every six months.

“Indiana and New Hampshire will review participants’ compliance each month between renewals, quarterly, and at renewal,” the report said. “Arkansas will also look back three months at the extension but does not plan for quarterly inspections. States that had not made a decision at the time of the survey included five states for an application, six states for an extension and seven states for more frequent inspections.”