CMS Guidance Expected on Medical Frailty Exemption Standards for Medicaid Work Requirements

States with approved Section 1115 work requirement waivers are developing processes to identify and exempt medically frail beneficiaries from compliance, but face operational questions about eligibility criteria, screening tools, and documentation requirements. CMS is expected to issue guidance addressing these implementation challenges. Early state approaches vary widely in how they define medical frailty beyond the statutory ACA definition, who conducts assessments, and how exemptions are renewed. The guidance will affect MCO responsibilities for identifying exempt members and coordinating with state eligibility systems.

Managed Care