By Dietrich Knauth
Arkansas is planning to implement new work requirements as a condition for Medicaid eligibility, and the change will pose challenges even to Medicaid recipients who are exempted under the new rules, since many of them are in poverty and lack resources to navigate the waiver process, according to a research report by the nonprofit Urban Institute.
Work requirements. CMS issued guidance in January 2018 that allowed states to make "work or other community engagement" activities a condition of Medicaid eligibility, a sharp break from Medicaid policy over the past 50 years. Eleven states have submitted proposals to CMS to add work requirements to their Medicaid programs, and Arkansas is expected to be the first state to implement them, with work requirements being partially phased in on June 1 before fully taking effect in 2019. For the first six months, Arkansas will exempt Medicaid recipients who are under 30 or over 50 from the work requirement.
Arkansas enrollee breakdown. The Urban Institute divided affected Arkansas Medicaid recipients into three broad categories: enrollees who are likely exempt from work requirements in Arkansas, enrollees who are not exempt but are working, and enrollees who are not exempt and not working. Although the third group is most likely to lose Medicaid coverage as a result of the rules change, all three are at risk for losing coverage under the new requirements, the Urban Institute found.
The first group is the largest, comprising about 74 percent of the state’s 269,000 nonelderly nondisabled Medicaid enrollees. That number will be higher initially, at 86 percent, while under-30 and over-50 enrollees are initially exempted from the work requirements. The exempt group includes children, elderly people (those age 65 or older), pregnant women, and those who are medically frail (with an acute condition that prevents them from complying with the requirements), or who qualify for Medicaid because of a disability. But even though members of this group are exempt from the work requirements, the Urban Institute expects that some will lose coverage because the process for obtaining the exemption will be "confusing and cumbersome" for some beneficiaries, especially given the high rates of poverty and serious health limitations within the exempt group, as well as a lack of reliable internet access.
The second group, working Medicaid participants, represents about 12 percent of Medicaid enrollees. They face the same challenges of complying with the work reporting requirements, and additionally may find themselves ineligible if their work is seasonal or offers inconsistent hours. Arkansas requires at least 80 hours of work or related activities a month and requires that enrollees meet this requirement for 10 months in the year, and it does not allow workers to "roll over" excess hours worked in a month to maintain their eligibility. That requirement doesn’t take into account the fact that many working Medicaid enrollees work more than 35 hours when they have work, and may not be able to work for a consistent number of hours throughout the year, according to the Urban Institute.
"Group 2 enrollees are working, but they may risk losing their Medicaid coverage throughout the year because of the high turnover and seasonality of certain low-wage occupations as well as the lack of affordable private health insurance options available to many low-wage workers," the report found. "The lack of consistent work hours among this population may reflect high rates of turnover in low-wage jobs or a high prevalence of seasonal work."
The third group, non-exempt and non-working enrollees, makes up about 15 percent of the total. In general, they have lower incomes, have less household internet and vehicular access, and have lower educational attainment levels than the other enrollee groups. They face high barriers to finding work, and even if they do, 31 percent have no home internet access, which may prevent them from submitting required online documentation of their hours worked each month, according to the Urban Institute.
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