Federal Guidance on Monitoring and Evaluating Work Requirements

Prepared with support from the Robert Wood Johnson Foundation

In March 2019, the Centers for Medicare & Medicaid Services (CMS) issued detailed guidance for states on the monitoring and evaluation of “eligibility and coverage” Section 1115 Medicaid demonstrations. The new guidance provides standard monitoring metrics and recommended research methods geared specifically toward state Medicaid demonstration waivers that include one or more of the following policies:

  • Work or community engagement (CE) as a condition of eligibility
  • Beneficiary premiums
  • Waivers of retroactive eligibility
  • Imposition of non-eligibility periods for failure to meet certain requirements
  • Premium assistance

The guidance from CMS marks a substantial increase in the rigor—and associated resource investments—demanded of states for monitoring and evaluating these types of demonstrations. To help state officials and their researcher partners navigate the heightened expectations, a new brief from Manatt Health, with support from the Robert Wood Johnson Foundation, provides an overview of the March 2019 guidance, distills key information on its new requirements and highlights practical considerations for states. While monitoring and evaluation requirements and resources are referenced more broadly, the brief has a particular focus on demonstrations with a work/CE component and is a complement to Monitoring and Evaluating Work and Community Engagement Requirements in Medicaid: Data Assets, Infrastructure and Considerations for States, an earlier resource guide also produced by Manatt Health with Robert Wood Johnson Foundation support.

The new CMS guidance includes three components:

  • An implementation plan template for work/CE demonstrations
  • A monitoring report template and associated metrics for eligibility and coverage demonstrations, including but not limited to those with work/CE policies
  • Evaluation design guidance specific to eligibility and coverage demonstrations, along with a more broadly applicable document on how states can plan the implementation of their demonstrations to enable rigorous evaluations

Read the full resource guide here.



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