Kentucky's Medicaid Work Requirement May Create Barriers for Beneficiaries

In Kentucky, Medicaid enrollees now facing a work requirement will experience barriers that limit their ability to reach the requisite 80 hours’ worth of “community engagement” activities or document exemptions including low educational attainment, health limitations, and a lack of access to a vehicle and the internet.

By the fifth year of Kentucky's implementation of work requirements in its Medicaid program, there is a predicted 15% drop in enrollment, according to research from Urban Institute. The researchers estimated 169,000 enrollees are potentially nonexempt from the program's new work requirements but are working, and 188,000 enrollees are potentially nonexempt and not working.

According to the new requirements, Kentucky Medicaid beneficiaries must participate in 80 hours’ worth of “community engagement” activities each month by either working, participating in community service, searching for jobs, attending school or vocational training programs, or receiving treatment for a substance use disorder Children under age 19, adults age 65 and older, pregnant women, full-time students, primary caregivers of dependents, and enrollees who receive disability benefits while also qualifying for Medicaid are not subject to Kentucky’s new work requirement to receive Medicaid coverage.

Medicaid nonelderly adult enrollees fall into 1 of 3 groups. Group 1 includes beneficiaries in school, primary caregivers of children, and primary caregivers of disabled dependents who would be exempt from the work requirement. Group 2 includes enrollees who fall into one of those 3 categories and are working. Group 3 includes enrollees who are not working or seeking work.

In 2016, 29% of all nonelderly adult Medicaid enrollees in Kentucky were not working and could potentially be nonexempt from the work requirement. Similarly, 26% of all nonelderly beneficiaries who were working would be nonexempt, as well. The main reason nonelderly adult enrollees would be exempt would be their status as the primary caregiver of a child.

The researchers determined that Medicaid enrollees will experience barriers that limit their ability to reach the 80-hour quota or document exemptions including low educational attainment, health limitations, and a lack of access to a vehicle and the internet.

The waiver will have the greatest impact on group 3 Medicaid beneficiaries. This group has a demographic that tends to be older, have lower incomes, have less internet and vehicle access, and have low education levels. Group 3 enrollees have a higher incidence of serious health limitations and chronic illness. Currently, it is unclear how Kentucky’s Medicaid program will determine if a beneficiary is medically too frail to perform the work requirement.

It is recorded that more than one-third of group 2 enrollees are not working at least 50 weeks a year and 20 hours a week, the recorded amount of work needed to waive the Medicaid work requirement. While many group 2 enrollees will work more than 36 hours during the weeks where they are employed, a monthly surplus of hours exceeding 80 hours will not carry over to the next month.

Due to the complexity of the new policy, Kentucky’s new Medicaid work requirement may create more barriers and confusion among enrollees who must document their hours on the internet despite clear communication by the state.

“Decisions the state makes as it operationalizes the waiver, such as those concerning exemptions; employment and training services, job search assistance, and related supports that will be available to enrollees; and documentation and reporting requirements and processes, will be critical to determining the impacts of these provisions on the health and well-being of low-income adults in Kentucky,” the authors concluded.


Gangopadhyaya A, Kenney GM. Who could be affected by Kentucky's Medicaid work requirements, and what do we know about them? Urban Institute. Published February 16, 2018. Accessed February 20, 2018.

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