Public Notice: South Dakota Proposed Medicaid 1115 Waiver Demonstration for Work Requirement

The South Dakota Department of Social Services (DSS) intends to submit an 1115 demonstration waiver application to the Centers for Medicare & Medicaid Services (CMS) to implement a new initiative known as SDCareerLink. This proposed demonstration introduces a work or community engagement requirement for adults eligible under the Medicaid expansion population. This change aligns with the will of South Dakota voters as expressed by the passage of Constitutional Amendment F.

Overview of the SDCareerLink Demonstration

The goal of the SDCareerLink demonstration is twofold:

1. To improve participants’ overall health and wellbeing through employment or educational activities.
2. To increase employment rates among Medicaid expansion enrollees.

Eligibility and Compliance

To satisfy the work or community engagement requirement, individuals must meet one or more of the following criteria:

• Be employed;
• Be enrolled in school, job training, or vocational rehabilitation;
• Meet work requirements under another qualifying program, such as SNAP, TANF, or unemployment insurance;
• Be a parent or nonparent caretaker of a dependent child living in the same residence;
• Be a primary caregiver for an elderly or disabled individual in the same residence;
• Qualify for an exemption.

Compliance with the requirements is not based on a monthly minimum number of hours and is not tied to monthly or quarterly reporting. Compliance will be verified at the time of the individual’s normal annual Medicaid renewal.

Exemptions

Individuals may be exempt from the requirements if they:

• Have been determined disabled or blind by the Social Security Administration;
• Are unable to work due to a serious illness or medical condition as certified by a physician;
• Are participating in an intensive or residential behavioral health treatment program;
• Are experiencing a medical emergency, hospitalization, or meet a nursing facility level of care;
• Are pregnant or within the postpartum period;
• Reside in an area with unemployment 20% or more above the national average and are exempt from SNAP ABAWD (Able-Bodied Adults Without Dependents) requirements.

Additionally, individuals may request a good cause exemption for extraordinary circumstances, such as a natural disaster, that prevent them from meeting the requirements.

Verification Process

The Department will use existing data sources where possible to verify compliance. If a participant appears not to meet the requirement at the time of renewal, they will be allowed to self-attest to compliance or to an exemption, supported by documentation. Those who do not self-attest or fail to provide sufficient documentation will be notified of the loss of Medicaid eligibility. They may regain eligibility upon meeting the program requirements or qualifying for an exemption.

Estimated Enrollment Impact

The Department estimates that approximately 80 percent of the expansion population already meets the requirement or an exemption, based on available data. Implementation of the demonstration is expected to result in a 5 to 10 percent reduction in enrollment during the first year. In subsequent years, enrollment is projected to remain flat rather than grow by the anticipated 2 percent.

Public Comment Period

A 30-day public comment period will be held from May 19, 2025, through June 18, 2025. During this time, the State will also conduct two public hearings:

• May 30, 2025, at 10:30 AM CST
  Department of Social Services – Kneip 1 Conference Room
  700 Governors Drive, Pierre, SD 57501
  Virtual participation available via Microsoft Teams
  Meeting ID: 283 311 942 692 1 | Passcode: LB7QM96p | Phone: 605-679-7263 / 241514796#
• June 12, 2025, at 11:00 AM CST
  Department of Social Services
  1501 S Highline Ave, Sioux Falls, SD 57110
  Virtual participation available via Microsoft Teams
  Meeting ID: 212 040 446 239 1 | Passcode: Uh6Y2Q9J | Phone: 605-679-7263 / 190017390#

The proposed demonstration application and full public notice are available for review on the DSS website: https://dss.sd.gov/medicaid/1115waiver.aspx

Written comments may be submitted via email to MedicaidSPA@state.sd.us with the subject line “SDCareerLink Public Comment,” or by mail to:

Division of Medical Services
Department of Social Services
700 Governors Drive
Pierre, SD 57501-2291