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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

Ohio House Bill 537: Proposed Regulations for Midwives and Birthing Centers

January 28, 2026House Bill 537, introduced in the Ohio House of Representatives, proposes a comprehensive regulatory framework for certified nurse-midwives, certified midwives, licensed midwives, and traditional midwives. The legislation would clarify scope of practice, establish licensure standards, and impose new requirements for freestanding birthing centers and home births. Healthcare providers and facilities should be aware of the proposed changes and their potential operational impact.Client Alert

Proposed Health Information Privacy Reform Act Expands Protections Beyond HIPAA

January 26, 2026The Health Information Privacy Reform Act (HIPRA) seeks to extend privacy protections to health data not covered under HIPAA, including data collected by apps and wearables. HIPRA introduces broader definitions of protected health information, strengthens privacy and security requirements, establishes patient notification rights, and sets national de-identification standards. Companies processing health data should monitor developments to ensure compliance.Client Alert

Medicare Updates on Skin Substitutes: LCDs Withdrawn, Payment Changes Take Effect

January 23, 2026Medicare’s planned Final Local Coverage Determinations (LCDs) for skin substitutes were withdrawn in late December 2025, meaning previous coverage rules remain in effect. The 2026 Medicare Physician Fee Schedule introduces a single payment rate of approximately $127.14 for these products. Providers should review implications for diabetic foot and venous leg ulcer treatments.Client Alert

Understanding the Seven Core Elements of an Effective Healthcare Compliance Program

January 22, 2026The Affordable Care Act requires healthcare providers participating in Medicare, Medicaid, and CHIP to maintain an effective compliance program. Guidance from the Department of Health and Human Services and the Office of Inspector General outlines seven core elements that form the foundation of these programs, from written policies and compliance oversight to auditing, training, and corrective action. This alert highlights each element and explains how practices can tailor compliance programs to their size and risk profile while meeting federal expectations.Client Alert

Preventing a Board Investigation

January 21, 2026Healthcare professionals in Ohio are subject to licensing board investigations that can lead to disciplinary action. Staying compliant with regulations, documenting carefully, and operating within your professional scope can help prevent issues. If contacted by a board, working with an attorney is critical to protect your license and rights.
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