CMS Approves Temporary Extension of “Georgia Pathways” Section 1115 Work Requirements Demonstration
This article was exclusively distributed to subscribers on September 29, 2025. Click to receive additional information about how to subscribe and to activate a complimentary trial subscription.
On September 23, CMS a temporary extension and amendment of the “Georgia Pathways to Coverage” section 1115 demonstration. The demonstration, which now runs through December 31, 2026, provides continued authority for Georgia to implement Medicaid work requirements for individuals ages 19 to 64 with household incomes up to 100 percent of the federal poverty level. Individuals must complete a minimum of 80 hours of qualifying activities (e.g., employment, community service, or participation in a job training program) unless they require a reasonable accommodation due to a disability or experience a good cause circumstance for noncompliance. The amended demonstration broadens the list of qualifying activities individuals can use to demonstrate compliance, decreases the frequency of required reporting, and terminates rather than suspends coverage for noncompliance. In its approval, CMS acknowledges that Georgia’s approved demonstration is not in compliance with H.R. 1’s work reporting requirements that go into effect on January 1, 2027, and that the state will need to prepare to align its program requirements to the federal statute.
The amendment adds two new qualifying activities to meet work requirements: 1) compliance with Supplemental Nutrition Assistance Program (SNAP) requirements; and 2) caregiving of a child under six who is currently enrolled in, or applying for, Medicaid. While compliance with SNAP requirements aligns with H.R. 1, the caregiving qualifying activity is more restrictive; H.R. 1 exempts parents of a dependent child who is 13 years or younger. The demonstration also updates its enrollee reporting requirements from monthly to annually, a shift that is more generous than H.R. 1’s every-six-months reporting requirements. In alignment with H.R. 1, individuals must report meeting qualifying activities for the month prior to application. Georgia’s list of good cause exemptions is broader than what is allowed in H.R. 1. Georgia’s good cause exemptions that are not allowable under H.R. 1 include: life events such as birth, adoption, or death of an immediate family member; being temporarily homeless; or experiencing a family emergency or other life event such as a divorce or being a victim of domestic violence.
Under Georgia’s first 1115 demonstration period (from July 1, 2023 through September 30, 2025), the state experienced a substantial level of coverage loss, with Medicaid expansion enrollment falling far short of projections. Only about were enrolled in Georgia Medicaid compared to over 300,000 who would have been eligible under full Medicaid expansion without work requirements. Many eligible adults were unable to obtain or retain coverage due to the onerous reporting and documentation burdens tied to the work requirement, resulting in significant gaps in access to care for low-income Georgians.
For more on H.R. 1’s work reporting requirements, Manatt on Health subscribers can see the Manatt on Health .
For more on the recent Government Accountability Office (GAO) analyzing the demonstration, Manatt on Health subscribers can see the September 22 of Insights this Week.
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