With federal work requirements set to go into effect in January, Ohio policymakers likely will be faced with a sharp increase in the state’s uninsured rate among Ohioans who have health challenges.

According to new projections from healthcare consulting firm Manatt, Ohio is expected to see its Medicaid enrollment drop by 305,000, or 10%, by 2028 because of the work requirements. Nearly all the people who lose their Medicaid coverage will become uninsured because they usually will not have access to other forms of health insurance.

Analysis conducted earlier this year found that those at risk of losing coverage tend to have greater health challenges than those who are at less risk to meet the work requirements, as illustrated above.

HPIO recently released a policy update on the implementation of Medicaid work requirements in Ohio. The publication focuses on Ohio's implementation of the H.R. 1 provision mandating that all states establish work requirements for Medicaid expansion eligibility by Jan. 1, 2027.

The 2014 expansion of Medicaid eligibility in Ohio contributed to the significant decrease in the state’s uninsured rate, particularly the percentage of working-age Ohio adults (ages 19 to 64) with lower incomes who are uninsured.

The new estimate from Manatt includes an additional 64,000 people losing coverage after an interim federal rule was released earlier this month that includes stricter criteria for receiving a medical frailty exemption. HR1 states that medically frail individuals, including people who are blind or disabled, or have a substance use disorder, disabling mental disorder, disability that significantly impairs activities of daily living or serious or complex medical condition, are exempt from meeting the work requirement.

Earlier Centers for Medicare & Medicaid Services (CMS) guidance indicated that states could use diagnoses to identify medical frailty. The new rule adds a further requirement: Individuals must show that their condition significantly impairs their ability to comply with the work requirements. That additional test does not appear in the statute and will require states to assess not only if someone has a serious condition, but whether that condition limits their ability to work, volunteer or attend school.