Avalere Health’s Eric Levine, M.P.H., on what stakeholders can do so people don’t lose coverage because of the Medicaid work requirements

CMS’ interim final rule on national Medicaid work requirements, released June 1, narrows who qualifies for the exemption meant to protect medically frail members, according to Eric Levine, M.P.H., principal at Avalere Health. The requirements, which CMS calls community engagement requirements, take effect in 2027 and apply to roughly 20 million people who became eligible for Medicaid through the Affordable Care Act's state expansions. To keep coverage, members in that population will generally need to show 80 hours of employment, community service or job training a month, though part-time school enrollment also satisfies the requirement.

In this excerpt from an interview with Managed Healthcare Executive, Levine discusses the new roles he sees for providers, health plans and life science companies in helping ensure that no one loses Medicaid coverage over documentation gaps rather than an actual failure to comply. He points to the Congressional Budget Office's estimate that 15% of the expansion population could lose coverage, with six to seven percentage points of that tied to procedural issues such as missed notifications or incomplete exemption paperwork rather than a decision not to work.

“Whether it's investing and supporting and or hosting job trainings that that meet the requirements, connecting with community-based organizations that connect members with volunteer opportunities that would meet the requirements, transition to work programs… I think that it's an opportunity for all stakeholders to invest around these activities to try to make this zero,” said Levine, referring to zero people losing coverage because of the work requirements.