ODM to Implement Medicaid Work Requirements: What Providers and Medicaid Expansion Recipients Need to Know
Client AlertOn March 11, 2025, Ohio Department of Medicaid (ODM) Director Maureen Corcoran appeared before the Senate Medicaid Committee to testify in support of Senate Concurrent Resolution 5 (SCR5) which urges the Trump Administration to approve ODM’s waiver that seeks to impose work requirements for the Medicaid expansion population in Ohio.
On February 28, 2025, ODM formally submitted its Section 1115 Demonstration waiver (the “waiver”) to the Centers for Medicare & Medicaid Services (CMS) to implement new work requirements for the Medicaid expansion population (also known as “Group VIII” recipients). Group VIII coverage includes adults ages 19 to 64 who are not eligible through other Medicaid categories and who make less than 138% of the federal poverty level (which, in 2025, is roughly $21,597 for a single person).
The state legislature included language in the budget bill passed two years ago that requires ODM to implement new eligibility criteria for Group VIII recipients. The new limitations memorialized in the waiver ODM recently submitted require that, to qualify for enrollment in Group VIII, a recipient must satisfy at least one of the following criteria:
- Be at least 55 years of age;
- Be employed;
- Be enrolled in school or an occupational training program;
- Be participating in an alcohol and drug addiction treatment program; or
- Have intensive physical health care needs or serious mental illness.
ODM was recently notified that the state’s waiver application has satisfied the completeness review and is now undergoing its federal public comment period. The comment period will end on April 7, 2025, and then the state’s waiver application will enter the review and negotiation period and formal review period. If the waiver is approved as submitted, the waiver’s first demonstration year will begin on January 1, 2026.
If you have questions about ODM’s proposed work requirements, or Group VIII coverage, or would like to submit comments to the federal government, please reach out to BMD Member Daphne Kackloudis at dlkackloudis@bmdllc.com or BMD Attorney Jordan Burdick at jaburdick@bmdllc.com.