CMS Constricts Medicaid’s Definition of Medical Frailty for Work Requirement Exemptions

The Centers for Medicare & Medicaid Services (CMS) issued an interim final rule on June 3 that attempts to narrow the definition of “medical frailty” for purposes of determining work requirement (or community engagement) exemptions for Medicaid beneficiaries in most states. Such states must comply with the work requirement rules by January 1, 2027, including developing lists of health conditions that constitute medical frailty. However, the rule prohibits states from categorically exempting beneficiaries with those health conditions and requires them to instead evaluate an individual’s ability to satisfy the work requirement based upon their overall health. Nonetheless, through 2027, the rule permits states to accept self-declaration of work or exemption status when reliable data are not otherwise available. Key provisions of the rule can be found in CMS’s Fact Sheet.