AHCCCS Works Waiver Amendment Request

In 2015, the Arizona State Legislature passed Bill 1092, requiring AHCCCS to submit to CMS three 1115 Demonstration Waivers that:

  1. Institute a work requirement for all “able-bodied adults” receiving Medicaid services,
  2. Place on “able-bodied adults” a lifetime limit of five years of Medicaid benefits,
  3. Develop and impose meaningful cost-sharing requirements to deter both the nonemergency use of emergency departments and the use of ambulance services for nonemergency transportation or when it is not medically necessary.

On December 19, 2017, AHCCCS submitted a formal 1115 Waiver Amendment Request titled “AHCCCS Works.” This amendment request would require non-exempt “able-bodied adults” between the ages of 19 and 55 to complete qualifying employment or educational activities for at least 20 hours per week to qualify for AHCCCS coverage.

On January 18, 2019, CMS approved Arizona’s “AHCCCS Works” request where the Demonstration Special Terms and Conditions specified that the state would implement the AHCCCS Works requirement no sooner than January 1, 2020. Implementation work for the program began and then was later halted in October 2019 due to ongoing litigation of similar Medicaid Work Requirement 1115 Demonstration Waivers. This program was then further delayed by the Public Health Emergency (PHE) in January 2020. The approval and subsequent authority for AHCCCS Works was then rescinded by CMS on February 12, 2021. Arizona has reviewed the previous 2019 submission and made modifications to reflect changes in Arizona’s population and workforce needs in this current waiver amendment request.

The AHCCCS Works requirements in this waiver amendment apply to all “able-bodied” members who are 19-55 years old, fall within the Medicaid new adult group (Group VIII), and are not otherwise exempt. The new adult group population includes individuals with incomes between 0 and 133% federal poverty level (FPL) — 138% including the 5% Modified Adjusted Gross Income [MAGI] income disregard — who do not qualify for Medicaid in any other eligibility category. These groups are often referred to in Arizona as the Proposition 204 group (0 - 100% FPL) and the Adult Expansion group (100 - 133% FPL).

“Able-bodied adult” members will be required to meet the following activities, or combination of activities, for at least 20 hours per week to qualify for AHCCCS

  • Be employed;
  • Attend school; or
  • Attending an Employment Support and Development (ESD) program. The definition of an ESD program includes:
    • English as a Second Language courses;
    • Parenting classes;
    • Disease management education;
    • Courses on health insurance competency; and
    • Healthy living classes.

The AHCCCS Works requirements will not apply to individuals who meet any of the following conditions:

  • Individuals who are at least 56 years old;
  • Individuals who qualify for services through the Indian Health Service or Tribally Operated Health Facilities, including but not limited to enrolled or affiliate members of federally recognized American Indian/Alaskan Native (AI/AN) Tribes;
  • Women up to the end of the 12-month postpartum period;
  • Former Arizona foster youths up to age 26;
  • Individuals determined to have a serious mental illness (SMI);
  • Individuals who are in active treatment with respect to a substance use disorder (SUD);
  • Individuals currently receiving temporary or permanent long-term disability benefits from a private insurer or the government;
  • Individuals who are receiving Supplemental Nutrition Assistance Program (SNAP), Cash Assistance, or Unemployment Insurance income benefits;
  • Individuals who are determined to be medically frail;
  • Full-time high school students who are older than 18 years old;
  • Full-time trade school, college or graduate students;
  • Victims of domestic violence;
  • Individuals who are homeless;
  • Individuals who have recently been directly impacted by a catastrophic event such as a natural disaster or the death of a family member living in the same household;
  • Parents, caretaker relatives, foster parents, and legal guardians (per A.R.S. 14-5209);
  • Individuals who are exempt from the Arizona Department of Economic Security (DES) Nutrition Assistance Work Requirement programs;
  • Individuals who were incarcerated within the last six months;
  • Veterans regardless of the discharge status; or
  • Caregivers of a family member who is enrolled in the Arizona Long Term Care System (ALTCS).

It is important to note that by limiting these policies to Group VIII, some of the populations listed above do not automatically fall under the AHCCCS Works requirement provisions by virtue of their eligibility category (e.g., parents and caretaker relatives, postpartum women, former foster youth). However, we are noting their exemption here for transparency purposes, particularly due to stakeholder concerns about applying the requirements to vulnerable populations.

In alignment with A.R.S. 36-2903.09, Arizona additionally requests the authority to “allow the [AHCCCS] administration to ban an eligible person from enrollment for one year if it is determined the eligible person knowingly failed to report a change in family income or made a false statement regarding compliance with the requirements of subdivision (a) of this paragraph.

AHCCCS will host several community meetings to provide the public with information about the proposed waiver amendment. These sessions will provide the opportunity for AHCCCS to hear from stakeholders, including members and their families, advocates, and providers.

Public Forum Meeting Meeting Dates & Times Meeting Web Link & Call-in Information
Tribal Consultation (Hybrid) February 4, 2025
8:30 a.m. — 4:30 p.m. AZ Time
Register in advance for this webinar

Or Join by phone (US): 1.669.900.6833 | 1.719.359.4580 | 1.253.205.0468 | 1.253.215.8782 | 1.346.248.7799 | 1.408.638.0968 | 1.669.444.9171 | 1.312.626.6799 | 1.360.209.5623 | 1.386.347.5053 | 1.507.473.4847 | 1.564.217.2000 | 1.646.876.9923 | 1.646.931.3860 | 1.689.278.1000 | 1.301.715.8592 | 1.305.224.1968 | 1.309.205.3325

Webinar ID: 843 0229 9804
Passcode: 002632912
In-Person Location:
Arizona State Capitol Complex
1700 W. Washington St., Phoenix, AZ 85007
AHCCCS Works Public Form #1 (Virtual) February 27, 2025, 1:00 – 3:00 p.m. AZ Time Register in advance for this webinar

Or Join by phone (US): 1.719.359.4580 | 1.253.205.0468 | 1.253.215.8782 | 1.346.248.7799 | 1.408.638.0968 | 1.669.444.9171 | 1.669.900.6833 | 1.507.473.4847 | 1.564.217.2000 | 1.646.876.9923 | 1.646.931.3860 | 1.689.278.1000 | 1.301.715.8592 | 1.305.224.1968 | 1.309.205.3325 | 1.312.626.6799 | 1.360.209.5623 | 1.386.347.5053

Webinar ID: 830 0081 5661
Passcode: 562924019
AHCCCS Works Public Form #2 (Hybrid) March 4, 2025, 1:00 – 3:00 p.m. AZ Time Register in advance for this webinar

Or Join by phone (US): 1.669.900.6833 | 1.719.359.4580 | 1.253.205.0468 | 1.253.215.8782 | 1.346.248.7799 | 1.408.638.0968 | 1.669.444.9171 | 1.646.931.3860 | 1.689.278.1000 | 1.301 715 8592 | 1.305.224.1968 | 1.309.205.3325 | 1.312.626.6799 | 1.360.209.5623 | 1.386.347.5053 | 1.507.473.4847 | 1.564.217.2000 | 1.646.876.9923

Webinar ID: 854 0884 1982
Passcode: 663014711
In-Person Location:
ADOT Training Facility
1130 N. 22nd Ave., Phoenix, AZ 85009
AHCCCS Works Public Form #3 (Virtual) March 13, 2025, 11:00 a.m. –1:00 p.m. AZ Time Register in advance for this webinar

Or Join by phone (US): 1.669.444.9171 | 1.669.900.6833 | 1.408.638.0968 | 1.346.248.7799 | 1.719.359.4580 | 1.253.205.0468 | 1.253.215.8782 | 1.564.217.2000 | 1.646.876.9923 | 1.646.931.3860 | 1.689.278.1000 | 1.301.715.8592 | 1.305.224.1968 | 1.309.205.3325 | 1.312.626.6799 | 1.360.209.5623 | 1.386.347.5053 | 1.507.473.4847

Webinar ID: 821 0229 8942
Passcode: 617282676

The public will have the opportunity to review and submit comments on the proposal at the public meetings and in writing via e-mail to waiverpublicinput@azahcccs.gov or mail to:

AHCCCS
C/O OOD-Division of Public Policy and Strategic Planning
801 E. Jefferson Street, MD 4200
Phoenix, AZ 85034

All comments must be received by March 20, 2025.