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Will Medicaid Work Requirements Snag People with Type 1 Diabetes?

We examine a federal policy shift that may affect the diabetes community.

Policy News Watch

On January 11th, Brian Neale, the director of the Center for Medicaid, sent out a letter to state Medicaid directors informing them that the Trump administration would allow states to impose work requirements for Medicaid recipients. The letter states that the goal of this policy shift is to “improve Medicaid enrollee health and well-being through incentivizing work and community engagement among non-elderly, non-pregnant adult Medicaid beneficiaries who are eligible for Medicaid on a basis other than disability.”

Since then, Kentucky has been granted permission to implement changes to its Medicaid program that include requiring work or community service for able-bodied, non-pregnant Medicaid recipients who are not the primary caregivers for their families. Politico reports that Arkansas, Indiana, Maine, Utah, and Wisconsin are waiting to hear back from the Trump Administration about making similar changes.

Those who argue for such a change say they are trying to make sure able-bodied, low-income individuals are not shunning work because of Medicaid benefits; they fear that the expansion of Medicaid coverage in some states under the Obama administration may disincentivize work for some individuals. Those who argue against a work requirement say that it might kick vulnerable families and individuals off Medicaid; they cite statistics that find that some 60 percent of Medicaid recipients already work themselves, and 88 percent of those who don’t report having an illness or disability.

There is concern that the new work requirement guidelines, as they are currently being interpreted, may cause some disabled or otherwise people with diabetes or other chronic conditions unable to work to be lumped into the camp of able-bodied Medicaid recipients, whether they are able-bodied or not. If Kentucky’s new work requirements are any indication, the new Medicaid rules will require doctors and administrators to determine what constitutes a true disability that would exempt Medicaid recipients from the work requirements. This could pose a problem, as not every doctor or bureaucrat may be versed enough in type 1 diabetes to make an informed decision. If the work requirement is not properly implemented, people who cannot work may be required to do so, or be kicked off Medicaid.

In his letter, Neale addresses the thorny issue of who is eligible and who is exempt from the work requirement:

States must comply with federal civil rights laws, ensure that individuals with disabilities are not denied Medicaid for inability to meet these requirements, and have mechanisms in place to ensure that reasonable modifications are provided to people who need them. States must also create exemptions for individuals determined by the state to be medically frail and should also exempt from the requirements any individuals with acute medical conditions validated by a medical professional that would prevent them from complying with the requirements.

The devil may be in the details, though, as pointed out by Bob Doherty, senior vice-president of government affairs and public policy for the American College of Physicians.


A recent study by the The Kaiser Family Foundation found that 36 percent of non-working Medicaid recipients listed an illness or disability as the reason they weren’t working. That was the most frequent response given for lack of employment, ranking higher than “taking care of home or family” (30%) and “going to school” (15%). The study’s authors warned that Medicaid work requirements may create trouble in the system.

“Implementing work requirements can create administrative complexity and put coverage at risk for eligible enrollees who are working or who may be exempt,” the authors stated.

There will almost surely be a court challenge to the work/community service requirement, but it make take some time for such a challenge to be settled. Also, the legal theory around disability laws and diabetes is still a work in progress, and it may require even more lawsuits to determine how much people with diabetes might particularly be shielded from the work requirements.  

We will continue to track this issue, and keep you posted on this and other legislative and policy changes that may affect people with type 1 diabetes.

-Craig Idlebrook

Photo courtesy of Mobilus In Mobile via Wikimedia Commons. 


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