2256 Pathways Qualifying Activities Reporting

Georgia State Seal

Georgia Division of Family and Children Services
Medicaid Policy Manual

Policy Title:

Pathways Qualifying Activities Reporting

Effective Date:

October 2025

Chapter:

2200

Policy Number:

2256

Previous MT Number(s):

MT 74

Updated or Reviewed in MT:

MT 77

Requirements

Pathways is an 1115 Demonstration Waiver that provides coverage to adults ages 19 through 64 with household incomes up to 95% of the Federal Poverty Level (FPL) plus the 5% income disregard if necessary and who meet all other eligibility requirements.

To be eligible for Pathways, A/Rs must also be Georgia residents, US citizens or lawfully admitted qualified immigrants, meet the threshold of at least 80 hours per month of qualifying activities, not be eligible for any other Medical Assistance COA, and not be incarcerated.

Basic Considerations

Qualifying Activities

To be eligible for Georgia Pathways an A/R must demonstrate that they are currently engaged in at least 80 hours per month of a qualifying activity or combination of activities.

Qualifying Activities include:

  • Unsubsidized employment, including self-employment

  • Subsidized private sector employment

  • Subsidized public sector employment

  • On-the-job training

  • Job Readiness - Refer to Chart 2256.2 - Qualifying Activities for details

  • Community service - Refer to Chart 2256.2 - Qualifying Activities for details

  • Vocational education training

  • Enrollment in an institution of higher education

  • Enrollment and active engagement in the Georgia Vocational Rehabilitation Agency (GVRA) Vocational Rehabilitation program

  • Compliance with Supplemental Nutrition Assistance Program (SNAP) Able-Bodied Adults Without Dependents (ABAWD) program through completion of a work activity.

  • Parent and Legal Guardian of a Child under Six Years of Age

For definitions and acceptable verification of each QA type, please see Chart 2256.2 - Qualifying Activities.

Qualifying Activity Hours at Application

A/Rs must report at least 80 hours of engagement in a qualifying activity or activities at application and provide documentation for verification that they meet the hours and activities threshold for the most recent four weeks available. The submitted four weeks must be within the eight weeks prior to the application date.

Qualifying Activities Hours Reporting

Once enrolled in Pathways, A/Rs are required to report and verify their hours and activities at intake, annual renewal, and within 10 days of a change.

How to report hours and activities

A/Rs receiving Pathways may report their qualifying hours and activities through multiple channels:

  • Customer Portal (CP): Members may attest to hours and activities for the past month and upload documentation (pdf, jpg, tiff, bmp, docx) through their CP account.

  • By Phone: Members may call to attest to their hours and activities but will need to submit supporting documentation via one of the other allowable channels.

  • In-Person: Members may attest to hours and activities and provide documentation at a local DFCS office. Documentation must be stamped upon receipt.

  • Paper/Mail: Members may attest to hours and activities using a standard form template with attached documentation and mail it to a local DFCS office.

Reporting Qualifying Activity Hours During Renewal

A/R must complete the hours and qualifying activities reporting requirements (self-attestation and documentation for verification) for the month prior to submitting the renewal to be determined eligible for Pathways at redetermination.

Changes in Qualifying Hours and Activities

Fluctuations in the A/R’s community engagement, either in number of hours or types of activities, is not considered a change in circumstances. This does not need to be reported if the A/R still meets the requirements of the program of at least 80 hours/month of engagement in qualifying activities.

Normal fluctuations include the following:

  • Minor changes in hours worked due to scheduling changes made by the employer

  • Vacation/sick leave taken within a calendar month

  • Short-term academic breaks (e.g., President’s Day, Spring Break) taken within a calendar month

The above list is not all-inclusive.

In the event the A/R incurs a change in their qualifying activities that results in not meeting the minimum hours threshold of at least 80 hours/month, the A/R has a responsibility to report this as a change in circumstance. The A/R may submit a Good Cause Exception request (if applicable).

When a Pathways member reports a change in circumstance(s) or a change in circumstance(s) becomes known to the agency resulting in the member no longer eligible for Pathways, the case should be updated appropriately to terminate from Pathways and/or CMD to another COA. If the agency is unable to determine if the member remains eligible based on the reported change(s), a Verification Checklist (VCL) should be sent requesting appropriate items to make an appropriate determination.

Good Cause Exception

A/Rs must attest to the hours and activities completed and submit supporting documentation validating hours and activities. If A/Rs fail to meet the threshold of at least 80 hours at renewal or at a reported change, they can submit a Good Cause Exception request for consideration to continue/reinstate eligibility. Good Cause Exceptions are temporary circumstances that prevent or diminish an A/R’s ability to fulfill the hours and activities threshold during the reporting period.

If the Good Cause Exception is submitted timely and approved, the A/R will not enter a suspension period in the month following non-compliance with hours and activities requirements. The A/R may only request a Good Cause Exception for the prior month of activities and hours. The timeline for reporting Good Cause Exceptions is the same as for reporting qualifying hours and activities stated in previous section Qualifying Activities Hours Reporting.

The A/R will be allowed up to 120 hours of Good Cause Exception hours per certification year even if no longer required to report monthly. The Good Cause Exception hours will reset upon the certification of a new Period of Eligibility (POE).

Good Cause Exception is NOT available at application.

Acceptable Good Cause Exception reasons are as follows:

  • Family emergency or life event

  • Birth, adoption, foster placement, or death of an immediate family member

  • Temporary illness/short-term injury

  • Serious illness or hospitalization of member or immediate family member

  • Natural or human-caused disaster

  • Temporary homelessness

  • Public Health Emergency (i.e. COVID-19)

  • Other (approved by State)

This list is not all-inclusive.

A/Rs must select one of the acceptable reasons for the Good Cause Exceptions, provide written explanations of the circumstances, indicate number of hours requested, and submit supporting documentation. A/Rs may request a maximum of 120 hours per certification period.

How to Request a Good Cause Exception

To make a Good Cause Exception request, the member must complete four requirements:

  • Select a reason for the Good Cause Exception from a list of pre-defined options

  • Provide a written explanation of the circumstance

  • Indicate the number of hours requested for Good Cause

  • Submit documentation to support the request

At the time of submitting the request, the member must attest that s/he was unable to fulfill their qualifying hours and activities due to the Good Cause reason that is selected.

The A/R may make a Good Cause Exception request at the same time as reporting their qualifying hours and activities.

The A/R may request a maximum of 120 hours of Good Cause Exceptions per certification year. If the cumulative total of Good Cause hours requested in a single certification year exceeds 120 hours, all subsequent requests will be denied. Members will not be able to request a Good Cause Exception if they have reached the 120-hour maximum. Good Cause Exception cannot be accepted at application.

The A/R may request a Good Cause Exception through the same channels used to report their qualifying hours and activities, as follows:

  • Customer Portal (CP): If the A/R reports hours below the 80-hour threshold, s/he will be prompted to make an exception request.

  • By Phone: A/R may request a Good Cause Exception over the phone but will need to submit supporting documentation via one of the other allowable channels mentioned above.

  • In-person: A/R may request a Good Cause Exception in-person and provide documentation at any county DFCS office. Documentation must be stamped upon receipt.

  • Paper/Mail: A/R may attest to Good Cause Exception on the standard form template (Form 996 - Pathways Good Cause RM and RA Form) when she or he reports their hours and activities and mail the form to any county DFCS office.

The A/Rs who submit a Good Cause Exception Request will be subject to audit and are informed of this requirement at initial application approval of Pathways.

If the A/R chooses the “Other” category as the reason for the Good Cause Exception request, a task will be created and routed to a caseworker to review and approve/deny the request.

  • If the exception is approved, the A/R will be granted up to 120 Good Cause hours, depending on the availability of hours, beginning the month following the month of non-compliance with the hours and activities reporting requirement. The A/R will be responsible fo reporting back when normal activity has resumed before coverage will resume.

  • If the exception is denied by the caseworker and there are no other qualifying activities reported that meet the minimum of at least 80 hours for the reported month, the A/R will terminate effective the month following the month of non-compliance with the hours and activities reporting requirement.

  • If a Good Cause Exception that requires staff review is not reviewed timely for continued coverage in the following month, the member will maintain coverage for the following month.

    • If the member does not comply with the qualifying activities reporting in the following month, or if the Good Cause Exception request is denied by the caseworker, then the member will enter suspension starting from the first of the following month.

  • A caseworker may grant Good Cause Exceptions for longer than a one-month period based on the unique needs of a member’s circumstance.

    • It may be required for a staff member to request permission from a supervisor to exceed the one-month period.

If the A/R requests Good Cause Exception hours in an amount that exceeds the total number of Good Cause Exception hours remaining in the A/R’s certification period, all the requested Good Cause Exception hours will be denied. Example: A/R has 10 Good Cause Exception hours remaining, A/R requests 20 hours for their reporting period. All 20 requested hours will be denied due to insufficient remaining hours.

Good Cause Exception requests received during the renewal month will be determined using the hours remaining in that certification period.

Verification of Good Cause Exceptions

Acceptable documentation for Good Cause Exception requests is defined as follows:

Chart 2256.1 - Good Cause Reasons and Acceptable Verification
Good Cause Reason Acceptable Verification

Family emergency or life event

  • Client statement with collateral contact

  • Clinician’s note

  • Court papers/Legal papers

  • Police report/Domestic disturbance report

  • Jury duty selection notice

Birth, adoption, foster placement, or death of an immediate family member

  • Birth certificate

  • Birth announcement

  • Adoption papers

  • Obituary

  • Death certificate

  • Caregiver placement passport (for foster placement)

Temporary illness/short-term injury

  • Clinician’s note

  • Employer/Supervisor statement

Serious illness or hospitalization of member or immediate family member

  • Clinician’s note

  • Employer/Supervisor statement

Natural or human-caused disaster

  • Client statement with collateral contact

  • State-issued executive order

  • Federally declared disaster

  • Property loss statement

Temporary homelessness

  • Client statement

  • Landlord letter

  • Lease document

Public Health Emergency (i.e. COVID-19)

  • Client statement with collateral contact

  • Clinician’s note

  • Employer/Supervisor statement

Other (approved by State)

  • Client statement with collateral contact

  • TBD (circumstance reviewed and determined acceptable)

Pathways Reasonable Modification

To qualify for Pathways, A/Rs must report at least 80 hours per month of engagement in a qualifying activity or activities before eligibility can be approved. All applicants must verify they meet the qualifying activities and at least 80 hours threshold for the most recent four weeks available within the eight weeks prior to an application.

If any Pathways Medical Assistance applicant or member with a disability who is no longer able to perform any work, education, or Qualifying Activity needs assistance to meet the minimum 80-hour Pathways Qualifying Activities requirement in a month, the applicant or member with a disability can make the following Reasonable Modification requests that are specific to Pathways Qualifying Activity:

  1. Additional time to meet the reporting requirements at application (applies to Pathways applicants);

  2. Additional time for a referral to GVRA (applies to Pathways applicants and members).

Please see Chart 2256.3 - Reasonable Modifications vs. Reasonable Accommodations as a quick reference to understanding Reasonable Modification requests.

Caseworkers will process, review, and make decisions on Pathways applicant and member requests for Reasonable Modifications specific to Pathways qualifying hours and activities requirement. See the following examples:

Example 1:

If a caseworker grants a Pathways applicant’s Reasonable Modification request for “additional time to meet reporting requirements at application,” this means that the caseworker would provide the applicant up to 90 additional days to meet the reporting requirements.

Example 2:

If a caseworker grants a Pathways member’s Reasonable Modification request for “additional time for a referral to GVRA” due to a disability, this means that the caseworker would allow the member to maintain Pathways coverage for up to 90 days while the member engages in GVRA’s intake process.

To meet the Pathways Qualifying Activity requirement with this Reasonable Modification, the Pathways member is responsible for complying with the GVRA intake process, enrollment, and participation.

In addition to the Reasonable Modification types listed above, Pathways applicants and members are afforded the same access to Reasonable Modifications that are available for all categories of Medicaid. (For examples, please refer to Section 2020 - Americans with Disabilities Act (ADA) and Section 504). If an applicant or member needs a Reasonable Modification or Communication Assistance, the applicant or member should contact his or her caseworker or call DFCS at 404-657-3433 or DCH at 678-248-7449. The applicant or member may also make the request online at dfcs.georgia.gov/adasection-504-and-civil-rights. If the applicant or member is deaf, hard-of-hearing, deaf-blind or have difficulty speaking, s/he can call DFCS at the numbers above by dialing 711 (Georgia Relay).

The definition of disability used in Pathways follows the Americans with Disabilities Act (ADA) definition which states that an A/R meet any of the following three criteria:

  • the A/R has a physical, mental, or sensory impairment that substantially limits one or more major life activities,

  • the A/R has a record of such impairment, or

  • the A/R is regarded as having such an impairment.

Please refer to Section 2020 - Americans with Disabilities Act (ADA) and Section 504. The Pathways definition of disability differs from the ABD definition of disability, which uses the Social Security Administration (SSA) definition of disability.

The caseworker will contact the potential Pathways eligible A/R to determine the next steps for the A/R’s Reasonable Modification request for Pathways qualifying hours and activities. The caseworker will:

  • Explain the qualifying activities and hours requirements for the Pathways program and collect additional information from the A/R that may be needed.

  • Provide information and resources to help the A/R get engaged with an activity.

  • Allow for additional time (up to 90 days from request) for the A/R to show compliance before making an eligibility determination, if necessary.

  • Provide a referral to GVRA Vocational Rehabilitation Program, if applicable.

Interview for Reasonable Modification for Pathways Qualifying Activity Requests

The caseworker will attempt to reach the A/R following the current practice of conducting two unscheduled telephone attempts prior to scheduling an interview with the A/R who is requesting a Reasonable Modification for Pathways qualifying hours and activities due to a disability. If the A/R is not reached after two telephone attempts, the caseworker will schedule an interview. The A/R will receive a notice with their scheduled interview time and contact information for the assigned caseworker. The notice will indicate that failure to complete the interview will result in a denial for Pathways Medicaid.

If the A/R is not reached after the scheduled interview, the caseworker may deny their application.

If a potential Pathways eligible A/R who has attested to having a disability and is not currently meeting the qualifying hours and activities threshold and did not request a Reasonable Modification for qualifying hours and activities, the caseworker – during the Pathways interview – is to inquire whether the A/R needs a Reasonable Modification because they are unable to meet qualifying hours and activities required for Pathways due to a disability. If the A/R declines or otherwise fails to indicate the need for a Reasonable Modification because they are unable to meet qualifying hours and activities required for Pathways due to a disability, then the application will be denied and referred to GA Access.

Providing Reasonable Modification for Pathways Qualifying Activity Requests at Application

If the A/R reports that they are able to meet the qualifying hours and activities for Pathways eligibility, the caseworker will offer information on potential resources available to help the A/R get engaged with employment, education, training, or volunteer activities, if needed.

The A/R’s Medical Assistance application will pend for up to 90 days to allow the A/R to demonstrate compliance of four weeks of engagement with the qualifying hours and activities threshold. If the A/R submits verification of compliance with the Pathways hours and activities requirement within the 90 days, the caseworker will approve the application for Pathways. If the A/R fails to submit verification of compliance with the Pathways hours and activities requirement within 90 days, the application will be auto denied.

Referral to GVRA

If the A/R reports that they are unable to meet the qualifying hours and activities requirement due to their disability, the caseworker will offer a referral to the GVRA Vocational Rehabilitation Program to assist the A/R with coming into compliance. If the A/R accepts the referral, the caseworker will make a referral to GVRA. The caseworker will obtain verbal consent prior to the referral that the individual consents to a referral to GVRA.

The Standard of Promptness (SOP) for processing of Pathways A/Rs who have been referred to GVRA is 90 days from the date of authorization of a referral to GVRA. A Pathways application will remain in “Eligible – Pending GVRA Enrollment Status” until the member’s referral to GVRA is dispositioned as enrolled or denied.

If an A/R is determined eligible and enrolled in services for GVRA, Gateway automatically updates the Medical Assistance application to indicate enrollment in GVRA, which is a qualifying activity for Pathways. If GVRA enrollment status is received manually, a caseworker will be able to update the case with GVRA enrollment information. The A/R will be enrolled in Pathways effective the first of the month following receipt of the eligibility determination and enrollment from GVRA.

If an A/R is currently active on Pathways and reports a change or during renewal state s/he is no longer able to continue to meet the qualifying activity hours due to a disability and is requesting a Pathways Reasonable Modification and accepts a referral to GVRA, the A/R would maintain his/her current Pathways eligibility until an enrollment determination is received from GVRA.

If an A/R is determined ineligible and therefore not enrolled for GVRA, upon receipt of this information Gateway will authorize a denial for Pathways and a denial notice will be sent. The denial notice will specify that an A/R is not eligible for Pathways for failure to meet the hours and activities threshold and that the agency has been informed of their denial from GVRA. The denial notice will include information regarding other workforce development resources, which is provided to all applicants who are denied for failure to meet the qualifying activities requirement.

If an A/R has been pending for Pathways due to a referral to GVRA, the A/R will continue to pend for Pathways until an enrollment status is received from GVRA.

Ongoing Pathways Eligibility for GVRA Clients

A/Rs who are eligible for Pathways due to being enrolled in GVRA will be considered meeting the hours and activities requirements for Pathways if they remain in compliance with the terms of the GVRA program. Enrollment in GVRA is considered a qualifying activity for Pathways. GVRA will notify Gateway through an interface (if consent was granted by A/R) when a Pathways program participant is no longer an active client with GVRA, either due to graduation from the program or due to disenrollment.

GVRA will send information to Gateway (if consent was granted by A/R) when a client is disenrolled from the GVRA Vocational Rehabilitation Program. Gateway will issue a notice informing the member that they are no longer an active client of GVRA and will need to come into compliance with the Pathways requirements through engagement in other qualifying activities in order to maintain eligibility.

The potential Pathways eligible A/R must consent to the release of their personal information to GVRA for the purpose of validating their enrollment in GVRA before Gateway can make any automated updates to the A/R’s case received from an interface with GVRA. For A/Rs who do not consent to the release of their information to GVRA, they will be responsible for providing all changes in their GVRA enrollment status to DFCS. A/Rs who are no longer enrolled in GVRA will be suspended pending proof of another QA. If the verification of another QA is not provided within the VCL due date, then the A/R will be terminated.

Reasonable Accommodations for Pathways Members

If an A/R is already enrolled in Pathways and develops a condition which is temporary and prohibits their monthly compliance with the qualifying hours and activities, they may request a Good Cause Exception from the qualifying hours and activities. For more information about Good Cause Exception please refer to Good Cause Exception section. However, if the A/R develops a physical or mental impairment that substantially limits one or more major life activity, the A/R may report a Reasonable Accommodation from their employer, educational institution, organization, or supervisor to maintain their current activity.

Reasonable Accommodations for Pathways only refers to changes made by an employer/supervisor/institution for an A/R with a disability to allow the person to work or engage in an activity. The A/R must request a Reasonable Accommodations directly from the employer/supervisor/institution or through GVRA. DFCS staff do not collect verification of disabilities for a Reasonable Accommodation nor make determinations on the types of Reasonable Accommodations that are necessary for the Pathways A/R to be able to engage in a qualifying activity.

The only circumstance in which DFCS needs to be informed about a Reasonable Accommodation made between the employer/supervisor/institution and the Pathways A/R is if the member has reduced work/engagement hours and will be unable to meet the minimum of at least 80 hours/month required for Pathways eligibility. In this circumstance, the A/R will report and provide verification of the Reasonable Accommodation granted by his or her employer/supervisor/institution and the caseworker will reduce the A/R’s monthly minimum qualifying activities and hours requirement to maintain ongoing Pathways eligibility accordingly.

Reporting/Requesting Reasonable Modifications and Reasonable Accommodations

To maintain eligibility, Pathways members must report a change in circumstance and request a Reasonable Modification or report that they were granted a Reasonable Accommodation that allows them to work fewer than 80 hours per month, using the same channels available for submitting Good Cause Exception requests (i.e., phone, mail, in-office, online portal).

Please see Chart 2256.3 - Reasonable Modifications vs. Reasonable Accommodations for an overview of how these terms are used for the Pathways program and as a quick reference to understanding Reasonable Modification requests and Reasonable Accommodations granted by employers/supervisors/institutions.

Chart 2256.2 - Qualifying Activities
Qualifying Activity Definition Acceptable Verifications

Employment

Full or part-time employment in the public or private sector that is not subsidized by a public program.

Employment in the private sector for which the employer receives a subsidy from public funds to offset some or all of the wages and costs of employing an individual.

Employment in the public sector for which the employer receives a subsidy from public funds to offset some or all of the wages and costs of employing an individual.

EIVS - Employer Income Verification System (Truv, Experian, and/or TransUnion)

Pay stubs

Written statement from source/employer

Gross earnings (if hourly pay is known)

Timesheet

Self-Employment

Earnings from an individual’s own business or self-employment work, as opposed to wages or salary from an employer. Some examples include but are not limited to owning one’s own business, cutting grass, collecting cans for recycling, babysitting, selling food items, taxi/food delivery service, etc.

Signed Standardized Work/Participation Calendar from member indicating hours engaged (Member may fill in a standardized worksheet template indicating total weekly hours worked per client/activity;

OR submit a snapshot of their actual work calendar from the reporting month (e.g., Photo of ledger of appointments or Screenshot of calendar with work activities)

On-the-job-training

Training in the public or private sector that is given to a paid employee while he or she is engaged in productive work, and that provides knowledge and skills essential to the full and adequate performance of the job.

Statement from supervisor sponsoring the OJT

Job Readiness

Activities directly related to the preparation for employment, including life-skills training, GED course enrollment, high school enrollment for 19-year-old, resume building, and habilitation or rehabilitation activities, including substance use disorder treatment. Rehabilitation activities must be determined to be necessary and documented by a qualified medical professional.

An inpatient Skilled Nursing Facility or hospital stay is considered a habilitation or rehabilitation activity under job readiness only at initial application. For each day of an inpatient Skilled Nursing Facility or hospital stay, an applicant may claim 4 hours towards their monthly Qualifying Activities requirement.

Members will be allowed to participate in job readiness for no more than a total of six weeks in any 12-month period.

Signed statement from Recognized Agency or Community Resource indicating hours engaged. (Recognized agencies include Georgia Department of Labor Career Center, Workforce Development Board, Georgia Vocational Rehabilitation Agency, Goodwill, and other agencies as authorized by the State)

Signed statement from habilitation/rehabilitation institution verifying hours in last four weeks

Community Service

Structures programs and embedded activities in which an individual performs work for the direct benefits of the community under the auspices of public or nonprofit organizations. Approved community service programs are limited to projects that serve a useful community purpose in fields such as health, social service, environmental protection, education, urban and rural development, welfare, recreation, public facilities, public safety, and childcare.

Georgia will consider, to the extent possible, the prior training, experience, and skills of an individual in making appropriate community service assignments.

Relative Caregiving through EDWP or SOURCE structured Caregiving Program is considered a qualified activity.

Signed Standardized Work/Participation Calendar

Signed statement on organization letterhead from supervisor verifying hours














Signed statement / record from the Structured Caregiving Program verifying the hours

Vocational Education Training

Organized education programs that are directly related to the preparation of individuals for employment in current or emerging occupations. Course hour requirements for vocational education training shall be determined by the Department of Community Health (DCH)*.

Electronic verification via Technical College System of Georgia (TCSG) data.

Official course enrollment for the current semester from the office of the Registrar or

Copy of class schedule for the current semester if unable to verify electronically, especially if the school is not in Georgia.

Enrollment in an Institution of Higher Education

Enrolled in and earning course credit at a college, university, or other institution of higher learning. A full-time academic workload, as determined by the Department of Community Health (DCH), will meet the requirements for at least 80 hours of qualifying activities in the month. For individuals not enrolled full-time, DCH shall determine the associated number of qualifying hours based on the course load when compared to full-time*. The student’s workload may include any combination of courses, work, research, or special studies that the institution considers contributing to an individual’s full-time status.

Electronic verification via Board of Regents (BOR) data.

Official course enrollment for the current semester from the office of the Registrar or

Copy of class schedule for the current semester if unable to verify electronically, especially if the school is not in Georgia.

Enrollment and active engagement in the Georgia Vocational Rehabilitation Agency (GVRA) Vocational Rehabilitation program

Enrolled in and compliant with the requirements of the Georgia Vocational Rehabilitation Agency (GVRA) Vocational Rehabilitation program. Individuals who are accepted in the program whose IEP is under development, or who comply with the terms of their IEP once completed, will satisfy the requirements of at least 80 hours of qualifying activities in the month.

Signed statement from GVRA, dated within four weeks of submission by the applicant

Enrollment letter dated within four weeks of submission by the applicant

Active status through agency interface (only if available)

Compliance with SNAP ABAWD program (SNAP Works)

Compliance with the eligibility requirements to receive SNAP benefits under the ABAWD program; a person participating in the SNAP programs must be in a work activity.

Active status through Gateway updates from SNAP Works

Parent and Legal Guardian of a Child under Six Years of Age

Parents and legal guardians who are primarily responsible for the daily care and well-being of a child younger than six years of age. The child under age six must be currently enrolled in the Medicaid program or must be on the Medicaid application also applying with the adult seeking Pathways coverag.

Active status through Gateway coding of appropriate screens/information for parents

Legal guardians verify with court order

For Vocational and Higher Educational Training, credit hour criteria is 1-5 credit hours = 20 QA; 6-11 credit hours = 40 QA, 12+ credit hours = 80 QA.
Chart 2256.3 - Reasonable Modifications vs. Reasonable Accommodations
Reasonable Modifications (All Programs) Reasonable Modifications (Additional for Pathways) Reasonable Accommodations

Use in Program

Available for all customers who indicate they have a disability and request a Reasonable Modification to apply for or stay compliant once enrolled for Medical Assistance.

Available for Pathways applicants and members who indicate they have a disability which prevents them from meeting the minimum qualifying hours and activities and request a Reasonable Modification

An agreement made between an employer/institution and a Pathways member that enables them to work or engage in an activity

Who Grants Request

All DFCS OFI Staff

OFI Eligibility Staff

Employer / Institution / Supervisor

Types Available

Examples of the types of Reasonable Modifications available to all Medical Assistance Applicants and Members (not a complete list):

  • Sign language interpreter

  • Cued speech interpreter

  • Oral interpreter

  • Tactile interpreter

  • Email

  • Face to face interview

  • Electronic communication

  • Teletypewriter (TTY)

  • Braille

  • Large print

  • Video Relay

  • Telephonic signature

  • Telephonic apps/renewals

  • Telephone call reminder of deadlines

Additional types of Reasonable Modification available for Pathways:

  • Pending the Pathways application up to an additional 90 days for the applicant to have additional time to report compliance with the qualifying hours and activities prior to determination

  • Pending the Pathways application up to 90 days while the applicant is referred and going through GVRA intake

  • Providing continued coverage up to 90 days while an enrolled Pathways member (who can no longer work/engage) is referred and going through GVRA intake.

Several types of Reasonable Accommodations may be made by the employer/institution to enable the A/R with a disability to engage (such as job restricting, low-tech roles, equipment)

Only one type of Reasonable Accommodation needs to be reported to the Pathways Medicaid program:

  • If the Reasonable Accommodation provided by the employer/institution is a reduction in hours the A/R is able to work/engage, which results in them not being able to meet the 80 hours/month minimum required to maintain enrollment in Pathways