By Virgil Dickson
September 26, 2018 - Modern Healthcare
Tennessee
officially posted its Medicaid waiver that would require enrollees to either
seek or maintain work.
It's the fourth state to propose a Medicaid work
requirement this month for comment. Alabama, Michigan and Virginia also posted
work requirement proposals on their Medicaid websites this month.
Tennessee's requirement will target TennCare-enrolled parents and caretakers
that are not pregnant, disabled or elderly adults.
Those enrollees
must engage in work or community engagement activities for an average of 20
hours per week. Qualifying activities can include paid employment, educational
activities, job searching or skills training activities, and community service.
Affected members must meet the requirement for four months of every
six-month period to maintain coverage. TennCare will assess member compliance
after six months of eligibility, and every six months thereafter.
Not
complying will cause benefits to be suspended. Coverage for those people will
remain suspended until they have complied with the requirement for one
month.
CMS Administrator Seema Verma has
expressed reluctance to approve work requirement waivers from non-expansion
states due to the so-called subsidy cliff; that occurs when a newly employed
enrollee begins to make too much money to be eligible for Medicaid, but still
too little to qualify for financial assistance on HealthCare.gov.
State
officials are optimistic they'll overcome the hurdle, according to TennCare
spokeswoman Sarah Tanksley.
Tennessee covers parents and caretakers to
just under the federal poverty level, versus other non-expansion states which
may set adult eligibility as low as 17% of the federal poverty
level.
"Given our coverage level for this population and the availability
of exchange subsidies beginning at 100% FPL, we believe we can avoid the subsidy
cliff that might be created elsewhere," Tanksley said.
The state will
accept comments on its waiver through Oct. 28, after which it will review and
address the feedback before sending the waiver to the CMS.