Monitoring and Evaluating Medicaid Work and Community Engagement Requirements

Prepared with support from the Robert Wood Johnson Foundation

Under Section 1115 of the Social Security Act, the Secretary of Health and Human Services is permitted to waive certain federal Medicaid requirements to allow a state to undertake an experimental, pilot or demonstration project that is “likely to assist in promoting the objectives of” the Medicaid program. In early 2018, the Centers for Medicare & Medicaid Services (CMS) issued guidance signaling its willingness to approve Section 1115 demonstrations that allow states to condition Medicaid eligibility on beneficiaries’ meeting work and community engagement (CE) requirements. Since then, CMS has approved requests to implement work/CE requirements in six expansion states (Arizona, Arkansas, Indiana, Kentucky, Michigan and New Hampshire) and two non-expansion states (Maine1 and Wisconsin) and is now in the process of reviewing similar demonstration requests from an additional ten states.

Because these demonstrations condition eligibility on beneficiaries’ complying with new administrative processes and engaging in work/CE activities consistent with state standards, and can result in substantial coverage losses, it is crucial to understand how these policies impact beneficiary coverage and whether they achieve intended goals with respect to health and financial independence. On March 14, CMS issued additional, more detailed federal guidance that lays out “rules of the road” for monitoring and evaluation of 1115 demonstrations containing work/CE requirements and certain other features.

In a new resource guide funded by the Robert Wood Johnson Foundation, Manatt Health examines monitoring and evaluation of work/CE demonstrations, which are untested in Medicaid. The guide reviews the data assets and infrastructure necessary to support states and their researcher partners in robust monitoring and evaluation efforts. It also discusses the ways in which monitoring and evaluation for work/CE demonstrations should differ from traditional approaches, drawing on discussions with state officials and researchers who are considering options for implementation and oversight.

Click here to read more.

1Governor Janet Mills has since notified CMS that Maine will not implement its approved waiver.



pursuant to New York DR 2-101(f)

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