CMS revoked work-related coverage requirements in Utah


Patrick Jones


The Centers for Medicare and Medicaid Services (CMS) revoked Utah’s community engagement requirements on Tuesday due to risk of “coverage losses and harm to beneficiaries” as a result of the COVID-19 pandemic. 


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CMS sent a letter to the Utah Department of Health’s Division of Medicaid and Health Financing in Feb. 2021 to announce CMS is currently determining whether or not to withdraw the approval.  

The waiver amendment, approved March 29, 2019, required adults 19 through 59 to participate in work-related community engagement activities. This requirement included employment, consistently applying for employment, completing employment training, or doing community service. 

The letter further discusses their reasoning:

“The COVID-19 pandemic has had a significant impact on the health of Medicaid beneficiaries. Uncertainty regarding the current crisis and the pandemic’s aftermath, and the potential impact on economic opportunities (including job skills training, work and other activities used to satisfy the community engagement requirement), and access to transportation and affordable child care, have greatly increased the risk that implementation of the community engagement requirement approved in this demonstration will result in substantial coverage loss.”

CMS found that all but a small minority in Utah were working full-time or would have been eligible for exceptions to this rule. The report stated:

“The study estimates that, in Utah, 22 percent (43 percent nationally) of Medicaid beneficiaries aged 19 to 64 without Supplemental Security Income (SSI) in 2019 were working full-time (at least 35 hours per week). Of those not already working full-time in Utah, two-thirds would likely qualify for an exemption: 19 percent of these individuals were sick or disabled, 26 percent provide care to a dependent, and 21 percent were enrolled in school. Moreover, 27 percent of individuals not already working full-time, were working part-time. These individuals may be prevented from working longer hours due to childcare responsibilities, health issues, issues related to the labor market (e.g., difficulty finding steady employment), or the nature of their employment (e.g., lack of control over work schedules).”

The report also outlined the early impacts of this requirement on other states and how it impacted significant losses of coverage. 

Early evidence said 18,000 people were disenrolled from coverage in Arkansas for not complying with the work requirement. The report said that many people failed to comply with the reporting requirement of this new rule and were disenrolled. 

During this time, the percentage of people who lost coverage in Arkansas fluctuated between 20 and 47 percent. 

CMS has recently revoked these requirements in other states as well.