State Policy
States Struggle to Define Disability Under Medicaid Work Requirements
State Medicaid agencies are determining which medical conditions qualify beneficiaries for exemptions from work requirements, creating inconsistent disability determinations. Some beneficiaries, including cancer survivors, are losing coverage after states conclude they are able to work despite ongoing health issues. The issue affects states implementing community engagement requirements and illustrates the operational challenges of administering medical exemptions at scale. These determinations directly impact coverage continuity for vulnerable populations and create administrative burden for states and health plans managing exemption processes.
Why it mattersState Medicaid agencies must develop clear disability criteria and exemption processes to comply with work requirement waivers while managing appeals, coverage disruptions, and potential litigation over eligibility determinations.