Ohio Submits 1115 Waiver Request to CMS With Medicaid Work Requirements

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On February 28, Ohio submitted a (the “Group VIII 1115 Demonstration Waiver”) to the Centers for Medicare and Medicaid Services to require Medicaid expansion-eligible adults ages 19 to 54 with incomes at or below 138 percent of the federal poverty line (FPL) to work or participate in school or an occupational training program in order to enroll in or renew Medicaid coverage. This proposal builds on and modifies Ohio’s , approved in 2019 under the first Trump Administration and later by the Biden Administration.

Under Ohio’s new waiver request:

• Beginning January 2026, Ohio would review data to determine whether individuals qualify for new or continued coverage in the Medicaid expansion group by working or being enrolled in school or job training, or meeting an exemption.
  • Individuals with household earned income would be presumed to be employed. (The waiver application does not establish a specified income threshold or minimum number of hours worked per month.)
  • Individuals would qualify for an exemption by participating in an alcohol and drug addiction treatment program, or by having intensive physical health care needs or serious mental illness. Ohio does not plan to provide other exemptions commonly included in prior work requirements waivers, such as exemptions for individuals who are residing in areas with high unemployment rates, experiencing homelessness or housing insecurity, pregnant (with some exceptions), or justice-involved.
  • Ohio also intends to use a third party vendor to review external data sources to identify individuals who are either compliant with or exempt from work-related activities. If data is not sufficient to determine eligibility, individuals would be given an opportunity to provide supporting documentation.
  • The state indicates it will further define eligibility criteria and exemptions in the waiver’s Special Terms and Conditions.
• For those found eligible for the Medicaid expansion group, the state would offer job training and employment support services in partnership with the state’s managed care plans.
• Individuals who are not found to be working, enrolled in school/job training, or otherwise exempt, would be denied coverage at application or terminated at annual renewal.

The federal for Ohio’s waiver application is open until April 7.

For example, Ohio will need to: confirm that individuals eligible for the Supplemental Nutrition Assistance Program and the Temporary Assistance for Needy Families program—programs that have strict work requirements—will qualify as “working”; determine any requirements for the number of credits/classes needed to be considered “enrolled in school”; and define what would qualify as an “intensive physical health care need.”

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