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ODM to Implement Medicaid Work Requirements: What Providers and Medicaid Expansion Recipients Need to Know

Client Alert
March 21, 2025

On March 11, 2025, Ohio Department of Medicaid (ODM) Director Maureen Corcoran appeared before the Senate Medicaid Committee to testify in support of Senate Concurrent Resolution 5 (SCR5) which urges the Trump Administration to approve ODM’s waiver that seeks to impose work requirements for the Medicaid expansion population in Ohio.

Doctor using virtual screen presses text: MEDICAID EXPANSION.

On February 28, 2025, ODM formally submitted its Section 1115 Demonstration waiver (the “waiver”) to the Centers for Medicare & Medicaid Services (CMS) to implement new work requirements for the Medicaid expansion population (also known as “Group VIII” recipients). Group VIII coverage includes adults ages 19 to 64 who are not eligible through other Medicaid categories and who make less than 138% of the federal poverty level (which, in 2025, is roughly $21,597 for a single person).

The state legislature included language in the budget bill passed two years ago that requires ODM to implement new eligibility criteria for Group VIII recipients. The new limitations memorialized in the waiver ODM recently submitted require that, to qualify for enrollment in Group VIII, a recipient must satisfy at least one of the following criteria:

  1. Be at least 55 years of age;
  2. Be employed;
  3. Be enrolled in school or an occupational training program;
  4. Be participating in an alcohol and drug addiction treatment program; or
  5. Have intensive physical health care needs or serious mental illness.

ODM was recently notified that the state’s waiver application has satisfied the completeness review and is now undergoing its federal public comment period. The comment period will end on April 7, 2025, and then the state’s waiver application will enter the review and negotiation period and formal review period. If the waiver is approved as submitted, the waiver’s first demonstration year will begin on January 1, 2026.

If you have questions about ODM’s proposed work requirements, or Group VIII coverage, or would like to submit comments to the federal government, please reach out to BMD Member Daphne Kackloudis at dlkackloudis@bmdllc.com or BMD Attorney Jordan Burdick at jaburdick@bmdllc.com.

Ohio Department of MedicaidMedicaidOhio MedicaidHealth LawDaphne Kackloudisjordan burdick
Client Alert

USCIS Policy Change Impacting Work Authorization: Advisory for Employers and Human Resources

December 8, 2025USCIS has issued a policy memorandum pausing immigration benefit processing for individuals from 19 high-risk countries and requiring a re-review of certain previously approved cases. This change may affect work authorization, employment verification, and workforce stability. Employers and HR teams should review impacted employees and update compliance procedures.Client Alert

CMS Releases CY 2026 Medicare Physician Fee Schedule Final Rule with Key Payment and Telehealth Updates

December 4, 2025CMS issued the CY 2026 Medicare Physician Fee Schedule Final Rule on October 31, 2025, with changes effective January 1, 2026. The Final Rule includes increases to the conversion factor, a new efficiency adjustment, updates to practice expense methodology, permanent telehealth policy changes, revised payment for skin substitutes, expanded rules for Part B drugs and biologicals, enhanced policies for Rural Health Clinics and Federally Qualified Health Centers, and new care management and behavioral health services.Client Alert

Ohio Department of Medicaid Updates: Key Changes to Physician Reimbursement Rates in Early Parenthood

December 3, 2025The Ohio Department of Medicaid has proposed amending Ohio Administrative Code Rule related to covered Medicaid reimbursements for physicians. Beginning on January 1, 2026, they are proposing an increase to rates for prenatal care, childbirth, and infant care and provider visits.Client Alert

Name, Image, and Likeness Agreements in Healthcare

November 14, 2025For example, some healthcare providers have begun to utilize "Name, Image, and Likeness" agreements to promote the brand they have created through their healthcare practice.  We have seen the most healthcare NIL activity with longevity and wellness providers, as well as orthopedics.Client Alert

Compounding GLP-1 Drugs - Recent Updates

November 13, 2025Recent guidance from the Ohio Board of Pharmacy (“BOP”) indicates that providers should generally use the FDA approved GLP-1 drug, rather than a non-FDA approved compounded version of the medication. Importantly, if a GLP-1 drug is commercially available, it cannot be copied through compounding. Currently, compounded copies of Tirzepatide and Semaglutide are not permitted.
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