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Work and Community Engagement Requirements for MO HealthNet

March 10, 2022
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WRITTEN BY Dr. Joshua Mueller and Dr. Ramon Martinez III

In 2018, states could seek federal approval to use work or community engagement requirements as a condition for Medicaid coverage. Seven states were approved for work requirements for Medicaid coverage by the Centers for Medicare and Medicaid Services (CMS), but have since suspended enforcement due to the COVID-19 pandemic and because the Supreme Court vacated or set aside a ruling on the constitutionality of Medicaid work requirements in Arkansas, Kentucky, Michigan, and New Hampshire. At the time, six other states were pending decisions on their waiver applications for work requirements, but CMS announced in March 2021 that they would reject these proposals and withdraw the existing approvals to implement work requirements. 


  • The MO HealthNet has enrolled 1,191,000 people in the state of Missouri, including 62,000 individuals in the adult expansion population, and has seen a 30% increase in enrollment since the start of the pandemic.
  • Implementation of Medicaid work requirements in Arkansas resulted in a 12% decrease in the number of adults receiving Medicaid coverage and no increase in employment after 18 months.
  • Work requirements for Medicaid may have an outsized effect on specific populations, including women, those 50+ in age, those with chronic diseases or substance use, and rural populations. 


  • Comprehensive studies on the effects of work requirements on Medicaid benefits are limited to one state (AR). Outreach and administrative processes have varied between states to inform of documentation changes.
  • Little is known about how many Medicaid recipients currently engage in community engagement activities.
  • The legality of work requirements in Missouri is unknown given that all state authority to implement requirements has been removed by the federal government.


This Note has been updated. See the previous version (published March 2021) here.

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