CMS guidance lets states use tier system to exempt medically frail Medicaid recipients from work requirements

The Centers for Medicare and Medicaid Services issued new guidance that permits individual states to apply a tiered approach when deciding which Medicaid enrollees qualify as medically frail and therefore exempt from the 20‑hour weekly work or volunteer requirement.

Under the tier system, a diagnosis of a qualifying condition can automatically place a recipient in a higher tier, granting an exemption without additional paperwork. States may use existing health data to assign tiers, aiming to streamline the process for both patients and providers.

Patient advocacy groups and some medical societies welcomed the change, describing it as a modest improvement over previous rules that were seen as confusing. However, experts warned that the tier model remains complex and that states have limited time to implement it correctly, raising concerns that some severely ill individuals could still lose coverage.