Michigan’s Medicaid Work Requirement Rescinded

The Biden administration informed the state of Michigan April 6 it had withdrawn approval of the state’s community engagement requirement for some adult beneficiaries of the Healthy Michigan Plan, also known as the work requirement. In a 64-page letter, the Centers for Medicare & Medicaid Services (CMS) issued a finding that the requirement to work, job train, attend certain types of education or participate in substance use disorder treatment “risks significant coverage loss and harm to beneficiaries.”

Michigan’s work requirement began in January 2020 but was halted by court order in March 2020. The Families First Coronavirus Response Act, which grants states an additional 6.2 percent federal match for the Medicaid program during the COVID-19 pandemic, prohibits reducing the enrollment of Medicaid beneficiaries effective March 2020. Michigan continues to accept the additional 6.2 percent funding, which is in force at least through the end of calendar year 2021, depending on the end of the declaration of the federal public health emergency.

Even without the requirements related to the extra federal Medicaid funding, the CMS determined that requiring work or other community engagement as a condition of eligibility for Medicaid is not likely to promote the objectives of the Medicaid statute. The authority to impose a work requirement is withdrawn immediately and applies beyond the time frame of the public health emergency. For more information about the CMS action to end Michigan’s Medicaid work requirement or the Healthy Michigan Plan, contact Laura Appel at the MHA.