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CMS announces new policy guidance for states to test community engagement for able-bodied adults

CMS announces new policy guidance for states to test community engagement for able-bodied adults

Will support states helping Medicaid beneficiaries improve well-being and achieve self-sufficiency

CMS today announced new guidance that will support state efforts to improve Medicaid enrollee health outcomes by incentivizing community engagement among able-bodied, working-age Medicaid beneficiaries. The policy responds to numerous state requests to test programs through Medicaid demonstration projects under which work or participation in other community engagement activities – including skills training, education, job search, volunteering or caregiving – would be a condition for Medicaid eligibility for able-bodied, working-age adults. This would exclude individuals eligible for Medicaid due to a disability, elderly beneficiaries, children, and pregnant women.

The new policy guidance sent to states is intended to help them design demonstration projects that promote the objectives of the Medicaid program and are consistent with federal statutory requirements. To achieve the objectives of Medicaid, state programs should be designed to promote better physical and mental health. 

“Medicaid needs to be more flexible so that states can best address the needs of this population. Our fundamental goal is to make a positive and lasting difference in the health and wellness of our beneficiaries, and today’s announcement is a step in that direction,” said Seema Verma, CMS Administrator. 

To date, CMS has received demonstration project proposals from 10 states that include employment and community engagement initiatives: Arizona, Arkansas, Indiana, Kansas, Kentucky, Maine, New Hampshire, North Carolina, Utah and Wisconsin. 

“Our policy guidance was in response to states that asked us for the flexibility they need to improve their programs and to help people in achieving greater well-being and self-sufficiency,” said Verma. 

Announcement of the new guidance delivers on the commitment made by Administrator Verma in her address to state Medicaid directors last November, to “turn the page” in the Medicaid program and give states more freedom to design innovative programs that achieve positive results for the people they serve and to remove bureaucratic barriers that block states from achieving this goal. 

Criteria and Parameters of the New Policy Guidance 

CMS has identified a number of issues for states to consider in the development of proposals to promote work and other community engagement among working-age, non-pregnant Medicaid beneficiaries not eligible for Medicaid on the basis of a disability. 

Meeting work and community engagement requirements should take into consideration areas of high unemployment or caregiving for young children or elderly family members. States will therefore be required to describe strategies to assist eligible individuals in meeting work and community engagement requirements and to link individuals to additional resources for job training, provided they do not use federal Medicaid funding to finance these services. 

CMS will support state efforts to align Medicaid work and community engagement requirements with SNAP or TANF requirements, where appropriate, as part of this demonstration opportunity. Aligning requirements across these programs may streamline eligibility and reduce the burden on both states and beneficiaries and help beneficiaries succeed in meeting their work and community engagement responsibilities.   

States must also fully comply with federal disability and civil rights laws and ensure that all individuals with disabilities have the necessary protections to ensure that they are not inappropriately denied coverage. States will be required to offer reasonable modifications to individuals with disabilities, and will be required to exempt individuals determined to be medically frail or who have an acute condition that a medical professional has determined will prevent them from complying with the requirements. 

Administrator Verma cited the Administration’s firm commitment to combat our nation's opioid crisis and the letter outlines that CMS will require states to make reasonable modifications for individuals with opioid addiction and other substance use disorders. These modifications may include counting time spent in medical treatment toward an individual’s community engagement requirements or exempting individuals participating in intensive inpatient or outpatient medical treatment, as well as supporting other state efforts. 

CMS also encourages states to consider a range of activities that could satisfy work and community engagement requirements. States should ensure that career planning, job training, referral, and volunteering opportunities considered to meet the community engagement requirement, and job support services offered in connection with the requirement, take into account people’s employability and potential contributions to the labor market. 

“States have the opportunity to help individuals improve and enhance the skills that employers truly value,” said Verma. “People who participate in activities that increase their education and training are more likely to find sustainable employment, have higher earnings, a better quality of life, and, studies have shown, improved health outcomes.” 

Medicaid Demonstration Projects

Section 1115 of the Social Security Act gives the Secretary of Health and Human Services authority to approve experimental, pilot, or demonstration projects determined by the Secretary to be likely to assist in promoting the objectives of the Medicaid program. Demonstrations, which give states additional flexibility to design and improve their programs, are also designed to evaluate state-specific policy approaches and better serve Medicaid populations.

Administrator Verma also announced that CMS has updated to give states a clearer indication of how their reform strategies under section 1115 should align with a core objective of the Medicaid program: serving the health and wellness needs of the nation’s vulnerable and low-income individuals and families. The revised website content signals a new, broader view of these demonstrations in which states can focus on evidence-based approaches that drive better health outcomes, and quality of life improvements, and support upward mobility and self-sufficiency.

On March 14, 2017, the Department of Health and Human Services and CMS issued a letter to the nation’s governors affirming the federal government’s partnership with states to improve the integrity and effectiveness of the Medicaid program for low-income people with Medicaid. The letter encourages states to bring forward proposals grounded in ideas that reflect the dynamics and culture of a state.

“This new guidance paves the way for states to demonstrate how their ideas will improve the health of Medicaid beneficiaries, as well as potentially improve their economic well-being,” said Brian Neale, CMS Deputy Administrator and Director for the Center for Medicaid and CHIP Services.  

To view a copy of the SMD letter # 18-002, please click here.