The Trump administration this week issued guidance giving the go-ahead to states seeking to impose work requirements on certain Medicaid beneficiaries. That guidance suggests that states should offer supports for beneficiaries subject to the requirement:

States will be required to describe strategies to assist beneficiaries in meeting work and community engagement requirements and to link individuals to additional resources for job training or other employment services, child care assistance, transportation, or other work supports to help beneficiaries prepare for work or increase their earnings. 

The catch: The Trump administration also made clear in its guidance that there will be no additional Medicaid funding to pay for these services.


Arkansas is one of nine states with requests pending for work requirements after Kentucky’s request was granted on Friday. The proposal put forth by Gov. Hutchinson would impose work requirements on many beneficiaries in the state’s Medicaid expansion program, known as Arkansas Works, which currently covers more than 300,000 low-income adults. However, the state will not be making a corresponding additional investment in funding for work support services such as job training for Medicaid beneficiaries.

Arkansas Advocates for Children and Families, in a recent report, predicted that this will be a problem:


Arkansas has indicated that it will work with the state Department of Workforce Services to provide these supports for Arkansas Works enrollees, but provides no additional funding for these functions. However, Workforce Services likely does not have the funding or capacity to deal with the populations that are currently subject to a work requirement, much less the additional burden Arkansas Works participants would represent.

State officials express confidence that existing state resources will provide adequate support. Currently, the state has a “work referral” program in place — Medicaid expansion beneficiaries are informed about existing job training and job-search assistance available at the state’s Department of Workforce Services. Around 16,000 of those individuals accessed services from the agency last year after the referral (around 4,000 reported finding a new job afterward). DWS services include job search assistance, resume building, interview preparation, career research, alerts about new job openings and opportunities, referrals to job training and placement opportunities, and connecting job-seekers and employers seeking to train and hire new unskilled workers. Caseworkers work one-on-one with job seekers at the 33 Arkansas Workforce Centers across the state. The agency also provides training in foundational skills that lead to Career Readiness Certifications for job seekers that employers can use to verify basic work readiness.

The state plans to continue to rely upon DWS to offer support services once the work requirements are in place, but there will be no additional funding or resources to the agency devoted to providing these services to more people.


“There’s no additional funding given to it,” said Steve Guntharp, DWS Deputy Director. “We’re going to handle it with our existing work staff. We don’t anticipate that as soon as the work requirements take effect that everybody shows up at the door at one time — we expect it to be a staggered event.”

In some cases, Medicaid beneficiaries seeking to meet the work requirements may also be enrolled in different federal assistance programs that have federally funded work support services available.

Guntharp said that Medicaid beneficiaries referred to DWS who are also eligible for the welfare program Temporary Assistance for Needy Families (TANF) will be assisted by federally funded TANF caseworkers. Those who are TANF eligible will also have access to more intensive work support services than DWS provides to other Medicaid expansion beneficiaries, including help with transportation and childcare. However, the number of TANF beneficiaries is relatively small — less than Arkansas 10,000 families. It’s also not clear how much overlap there will be: TANF, which has its own requirements for work-related activities after 24 months, is only available for pregnant women and families with dependent children, who would be able to file for an exemption from the new Medicaid work requirements that Hutchinson is proposing for Arkansas Works.

Department of Human Services spokesperson Amy Webb said that in addition to the services offered by DWS, state officials believe that services currently available to SNAP (food stamp) beneficiaries will help many of the Medicaid beneficiaries subject to work requirements. The eligibility for the federal SNAP program is similar to Medicaid expansion eligibility, so unlike TANF, there will be a significant amount of overlap — most Medicaid beneficiaries are also SNAP eligible (I’ve asked DHS for the specific number of dual enrollees and will update when I receive a response).


Medicaid beneficiaries who are also on SNAP will be able to access the federally funded SNAP Employment and Training program, which offers support services including independent job searches, job search training, GED, vocational training, English as a Second Language (ESL), work experience, on-the-job training, job retention, and occupational skills. (SNAP has its own requirement for work activities after 3 months.)

The SNAP Employment and Training program is currently available in 37 counties. Webb said DHS has plans to expand the program to 13 more counties in the coming months.

Webb said that DHS is planning to do education and outreach before the work requirements begin, with the assistance of the nonprofit Arkansas Foundation for Medical Care and the private insurance companies that provide coverage for beneficiaries (under the state’s hybrid version of Medicaid expansion, Medicaid funds are used to purchase private health insurance plans for eligible Arkansans). She said that DHS has “developed a resource map/directory that identifies employment opportunities and available support services by county.”

Under the governor’s proposal, those between the ages of 18-49 would be required to work 80 hours per month. If they are not working or full-time students, they would have to meet the requirements by participating in job training programs, job searches, wellness programs, or certain approved volunteer activities. Beneficiaries must be in compliance for nine months out of the year or they would be removed from the program for the duration of the year.

Beneficiaries 50 or older would not be subject to the work requirement. Exemptions would be available for others who met certain criteria, including full-time students, those caring for an incapacitated person, those caring for dependent children in the home, people receiving unemployment benefits, those who are medically certified as incapacitated due to physical or mental health problems, those participating in a drug or alcohol addiction treatment program, and pregnant women. DHS projects that around half of Arkansas Works beneficiaries would be eligible for an exemption.

Beneficiaries will have to report their work activity via a website on a monthly basis (those who are exempt will have to report, verify, and periodically update their exemption status). Kiosks will be available in county offices for people who can’t access the site via a computer or other device.

The governor’s proposal is still awaiting approval from the feds. DHS has said that it will take 60 days to implement the changes once federal approval is secured. The plan is to phase in the work requirements program over six months for 30-49-year-olds in 2018, and phase it in over six months for 19-29-year-olds in 2019.