The Indiana Family and Social Services Administration (FSSA) has not yet finalized who will qualify for a "medically frail" exemption from the Healthy Indiana Plan (HIP) work requirements, with the rules scheduled to take effect in just three months. Thousands of low-income Hoosiers on HIP could be subject to these new mandates starting January 1.
HIP is a Medicaid plan designed for able-bodied adults aged 19-64 who earn slightly too much to qualify for traditional Medicaid. To maintain coverage, members will need to demonstrate 80 hours per month of work, volunteering, or school enrollment for three months leading up to their application or redetermination. Alternatively, earning at least $580 per month, equivalent to 80 hours at minimum wage, would also fulfill the requirement.
A significant exemption exists for adults deemed too medically frail to comply with the work requirements. However, the definition of medical frailty is currently in flux, causing considerable confusion for social workers, non-profit groups, and medical providers across the state. The federal Centers for Medicare and Medicaid Services (CMS) is actively redefining medical frailty as states, including Indiana, begin to implement Medicaid work requirements outlined in last year’s One Big Beautiful Bill Act.
Sunshine Beam, director of the Division of Family Resources at Indiana FSSA, indicated that the criteria are changing. Beam stated that individuals considered medically frail today might not meet the definition come January. This uncertainty was a consistent point of discussion at a town hall hosted by FSSA on Monday at the Indiana Government Center in Indianapolis, aimed at addressing questions about the upcoming changes.
Historically, various debilitating conditions such as blindness, substance-use disorders, severe mental illness, and other disabilities or complex medical conditions have qualified individuals as medically frail. Shawn Delmolino, a licensed social worker for the LifeCare HIV clinic at IU Health, noted that HIV previously fell under the medically frail category, but its status is now uncertain. Delmolino expressed deep concern for clients, particularly those experiencing homelessness, who already face significant barriers to employment and could become uninsured.
The interim final rule from CMS has narrowed the definition of medical frailty. It now specifies that only conditions significantly impairing a person’s ability to meet work requirements can be excluded, leaving states to determine the specific conditions that will qualify. An email sent by FSSA to HIP members and providers on Monday confirmed that the agency is still working with CMS to finalize these exclusions and promised further guidance in the future.
The new requirements pose particular challenges for homeless Hoosiers. Cagney Gladin, a fellow social worker with the LifeCare clinic, highlighted that these individuals often struggle to secure employment and may not receive important notices about their HIP coverage if they lack a stable address. Gladin also raised questions about a potential probationary period for Hoosiers who previously qualified as medically frail, given the three-month lookback period that effectively begins in October for January applicants.
Beam confirmed there would be "no workarounds" for those who previously met medically frail status but might not under the new definition, acknowledging that the prospect of these Hoosiers becoming uninsured is a concern for FSSA. Beam stated, "Unfortunately, there are going to be situations where our hands are tied," despite efforts to follow the law and do what is right.
When asked about retired Hoosiers drawing early Social Security, Beam explained that most would likely meet the monthly $580 income requirement. For others, volunteering could fulfill the work mandate; however, Beam clarified that activities like mowing a neighbor's lawn would likely not qualify, while work with a non-profit or church group might.
The FSSA continues to navigate the complexities of these new rules, with significant implications for up to 300,000 Hoosiers potentially facing the Medicaid work mandate. The ongoing redefinition of medical frailty remains a critical element for thousands relying on HIP coverage.
