Idaho 1115 Waiver Application

October 11, 2019


On September 27, 2019, Idaho submitted a new section 1115 waiver application to the Centers for Medicare and Medicaid Services (CMS).  The waiver seeks approval to establish a work requirement for certain eligible Medicaid beneficiaries in the Adult Expansion Group.  (The state’s Medicaid expansion has a targeted start date of January 1, 2020. This work requirement waiver is a five year demonstration that is expected to be fully implemented around month six after its approval.) CMS is accepting comments on the application from October 3rd, 2019 through November 2nd, 2019.

Below please find our summary of key points of the waiver.

Work Requirements

Through the 1115 Waiver, Idaho is proposing to implement Medicaid work requirements for certain Medicaid beneficiaries in the adult expansion group.  The following beneficiaries will be excluded from the work requirements: individuals under 19 years of age, individuals over 59 years of age, individuals who are physically or intellectually unable to work, individuals who are pregnant, parents or caretakers providing for a dependent under 18 years of age, individuals applying for or receiving unemployment compensation, individuals applying for Social Security Disability benefits, individuals participating in a drug or alcohol treatment and rehabilitation program, and American Indians or Alaska Natives eligible for services through the Indian Health Service or tribal health program.

Individuals who do not meet an exempt category and who are enrolled in the Idaho Medicaid program will be required to meet the work requirement.  Work requirement compliant activities include: employment, participation in a work training program, volunteer work, enrollment in a post-secondary education program, and compliance with a workforce program for Temporary Assistance for Needy Families or the Supplemental Nutrition Assistance Program.  Enrollees will be required to participate in 20 hours of work/community engagement activities each week to remain eligible for Medicaid benefits.

The Idaho Department of Health and Welfare (IDHW) will create reporting options for non-exempt beneficiaries to report work or community engagement activities in compliance with the requirements.  Non-exempt adults will be required to submit these reports monthly to IDHW.  Otherwise eligible beneficiaries who fail to comply with requirements shall be ineligible for Medicaid for a period of two months.  Individuals may reapply for Medicaid after two months from the date of ineligibility, or upon demonstrating compliance with the requirements or exemption.  Since individuals may reenroll in Idaho Medicaid by demonstrating compliance at any time within the two month penalty period, this penalty period is not a fixed eligibility lock-out.  IDWH will verify compliance every six months.

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