Eric Levine, M.P.H., on state flexibility in applying Medicaid work requirements

The CMS has released its Interim Final Rule for Medicaid work requirements, which will require certain adult Medicaid applicants and enrollees to complete 80 hours per month of work, education or community service to qualify for coverage. The rule creates a nationwide framework for work requirements, or what CMS is calling “community engagement.”

But in an interview with Managed Healthcare Executive, Eric Levine, M.P.H., a principal at Avalere Health, said the rule leaves for room plenty of state-to-state variability. CMS, for the most part, declined to define a specific list of qualifying medical conditions, offering only examples, which means states can and likely will build their own lists of what counts as a serious medical condition, he said. How narrow or broad those lists turn out to be, Levine said, will likely track each state’s underlying philosophy on the exemption.

The bigger source of variation, in Levine's view, may be how states design verification: how frequently they check compliance and what data sources they draw on to do it. Some states already have a health information exchanges they can lean on while others may stand up new databases or create data feeds so health plans and providers can submit information directly. Levine discussed the limitations of Medicaid claims and encounter data.