Work Reporting Requirements: State Considerations When Defining Medical Frailty

Patti Boozang, Kinda Serafi, and Emily Carrier, Manatt Health

H.R.1 establishes work reporting requirements as a new condition of Medicaid eligibility for expansion adults and individuals eligible for expansion-like coverage through a section 1115 waiver. The law provides that certain individuals, including those who are medically frail or otherwise have special medical needs, should be exempt from the new eligibility condition. To supports states in developing medical frailty definitions for work reporting requirements, the SHVS and Manatt teams developed a medical frailty toolkit that is based on a review of publicly-available policy guidance, information from states’ existing definitions of medical frailty, and research on clinical conditions. This toolkit provides a description of the factors such as increased risk of unemployment for reasons beyond an individual’s control, such as stigma and discriminatory hiring practices, that states may want to consider as they define the term for purposes of each of the key sub populations identified in H.R.1.

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