Ohio Medicaid submits Group 8 work‑requirement demonstration to CMS; expert warns budget risks in House Bill 96

Director Corcoran, director of the Ohio Department of Medicaid, said the agency submitted its Group 8 eligibility and “community engagement” demonstration to the Centers for Medicare & Medicaid Services in line with a House Bill 33 requirement and outlined the state’s estimates and implementation plans.

Corcoran told the Joint Medicaid Oversight Committee that, using current definitions and conservative assumptions, the department estimates roughly 800,000 Ohioans meet the new Group 8 eligibility criteria and that a substantial share — about 41 percent — are already working. He said about 45 percent of Group 8 enrollees receive behavioral health treatment services and roughly 15 percent receive substance use disorder treatment.

“The waiver was submitted in accordance with the timeline specified in House Bill 33,” Corcoran said, adding that the department presented maps and data to show geographic variation in need and likely assessment burden. He said the federal public comment period on the submission is open and that CMS’s comment window closes on April 7.

Why it matters: House Bill 33 directed the Department of Medicaid to submit the Group 8 demonstration, which establishes new eligibility limits tied to work, age and health conditions. If approved, the demonstration would change how some adults gain and retain coverage and require county and managed care organization involvement for eligibility assessments and care coordination.

What the department told the committee

- Eligibility profile and uncertainty: Corcoran emphasized the numbers are estimates because final regulatory definitions will be set by CMS. He said the department’s profile shows a slightly higher share of men than women in Group 8, about 9 percent aged 55 or older, and a group with higher-than‑average rates of chronic illness (he cited a roughly 12.6 percent share with severe chronic conditions or serious mental illness). He cautioned the department will need to refine definitions — for example, whether substance‑use criteria include only inpatient/residential treatment or also community programs.

- Who will need assessments: The department identified a subset of enrollees who will require additional documentation or screening at renewal. Corcoran and Deputy Director and Policy Chief Patrick Beatty described that subset as including people who are homeless or in shelters (estimated roughly 10 percent of that group), veterans (an acknowledged undercount), people with recent hospital or nursing‑home stays, parents of young children (the department used Ohio employment protections to define parents of children under age 9), and people on Supplemental Security Income or in custodial living arrangements. Corcoran said about 23 percent of the group are exempt from work requirements under existing SNAP/TANF rules.

- Process and partners: Corcoran said the department will fold new criteria into the routine annual renewal (redetermination) process for people already enrolled, and will apply the criteria at initial application for new entrants. He said managed care plans will be required to have trained staff who can coordinate with local jobs agencies (Ohio Means Jobs/JFS) and that the department plans to minimize face‑to‑face contacts by maximizing data matches where appropriate. Beatty described the department’s use of multiple administrative data sources (Social Security Administration, state unemployment, inter‑state files) to verify self‑attested facts.

- County and IT workloads: Committee members pressed the department on implementation capacity. Corcoran said the department is building on prior IT planning and work done for earlier demonstrations and that some planning and requirements design are already under way; final IT changes will depend on CMS approval. Corcoran also said counties will bear much of the assessment workload and that the department can provide county‑level dashboards to show expected assessments by county.

Budget, public comments and lessons from other states

- Public comments: Corcoran said the state received hundreds of public comments during its state comment period and summarized common themes: concerns about administrative burden and loss of coverage harming health outcomes; childcare and transportation barriers; and opposition questioning the effectiveness of work requirements. Supportive comments cited beliefs that work should be required for benefits.

- Budget estimates and uncertainty: Corcoran presented a budget build that includes state general revenue funding for administration, county assessment payments, IT changes, and estimates of the fiscal effect of disenrollment. He cautioned estimates vary depending on definitions and implementation timing.

- Lessons from other states: Corcoran reviewed Georgia and Arkansas experiences, saying Georgia spent tens of millions on administration and reported high administrative costs and limited enrollment in its voluntary pathway program; Arkansas showed rising uninsured rates in a specified age band after implementing a demonstration and little evidence of employment gains. Corcoran used those experiences to argue for minimizing administrative burdens and leveraging data matches.

Expert testimony and broader budget warning

Greg Moody, former executive director of the governor’s Office of Health Transformation and now at the John Glenn College of Public Affairs, told the committee Medicaid expansion brought coverage and federal dollars that stabilized hospitals and increased access to behavioral health and substance‑use treatment. Moody said Ohio’s expansion currently covers roughly three‑quarters of a million people and brings billions of federal dollars into the state each year.

Moody warned against a provision in House Bill 96 that would automatically discontinue the expansion if federal funding for the program fell below 90 percent. “That kill switch could wipe out a decade of progress,” he said, and urged the legislature to change mandatory language (“shall discontinue”) to discretionary language (“may reconsider”) so the state can weigh options if federal match rates change. He said replacing mental‑health and addiction services supported by expansion would cost at least several hundred million dollars and would more than offset the modest direct state savings from ending expansion.

Moody also outlined other budget drivers: recent across‑the‑board provider rate increases and implementation problems in “NextGen” projects (single pharmacy benefit manager and a new centralized fiscal intermediary) that produced higher pharmacy spending and claims payment delays. He urged continued oversight of the single PBM and the fiscal intermediary and recommended targeted, not blanket, rate increases where access problems exist.

Committee questions and follow-up requests

Committee members asked for more detail on: the extent to which prior IT work can be reused, county‑level assessment estimates, the cost and feasibility of more frequent redetermination cycles, and the fiscal exposure if federal match rates fall. Corcoran agreed to provide county maps of expected assessment volume and to model redetermination‑frequency costs. Moody recommended the committee require clearer accounting of PBM and NextGen spending and suggested the committee consider the wider fiscal tradeoffs before changing expansion policy.

Ending note

The department characterized its Group 8 submission as a data‑driven application aimed at maximizing federal match while minimizing unnecessary administrative contacts. The committee requested additional county‑level and cost analyses as the state moves from the public comment phase to detailed federal negotiations with CMS.