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By Marcie Timmerman, CEO of MHA Kentucky

A growing trend in state and federal Medicaid policy is the establishment of “work requirements” or “community engagement requirements”. Essentially, these involve requiring recipients to report a certain amount of work, education, or volunteer hours or they lose health care coverage.

Everyone agrees people who can work should do so. In 2017, the Kaiser Family Foundation found Medicaid recipients who can work already do. In fact, only 6% of all Medicaid recipients are not working. Of those working, 42% are working full-time but at low-wage positions.

Medicaid work reporting policies are “one-size-fits-all” requirements based on flawed assumptions and negative stereotypes. These policies do not provide funding for supported employment operations, incentives for employers to hire Medicaid recipients, banning the box, or any number of policies that would address the systemic problems faced by the 6% of national recipients who are not working. Many of these people would like to work, and could do so with support, some can’t due to disability.

Work reporting requirements create unhelpful red tape for working families. The more barriers we put between people and coverage, the more likely they are to forego preventive healthcare. This increases our overall healthcare systems costs. In the case of mental illness, it likely also increases our incarceration costs as individuals with mental illness too often are incarcerated when they are unable to receive treatment.

These requirements also come with a hefty administrative price tag. In Kentucky, for example, we know the information systems costs to establish work reporting requirements needed $17.5 million to be added to the biennium budget passed in 2018.

At Mental Health America, we promote prevention and early identification of mental health conditions: timely access to integrated treatment to keep people housed, in school and working, and to prevent incarceration, debilitation or hospitalization: and we know that recovery is the goal.

Setting up roadblocks to early assistance for anyone is unacceptable. There are far less costly and more effective solutions to support wellness and employment than work reporting requirements.

Facts About Medicaid Work Reporting Requirements

Most adult Medicaid beneficiaries are already working. Taking this coverage away from hard-working people close to or below the poverty line will hinder their ability to stay well enough to continue working.

Taking away coverage from low income adults -- many of whom are parents--will end up being more expensive in the long run for all levels of government, further eroding resources for other needs.

Persons with disabilities will lose coverage because they don't know how to claim an exemption from complicated work requirements.

New layers of bureaucratic red tape and complicated reporting systems ensure that many will lose coverage through no fault of their own, even when they try to follow all the rules.

Lessons Learned so far in the 1115 Waiver Implementation in Kentucky

Know the exemption definition being used for “medically frail” and get involved in the process of defining it. We’ve been able to include victims of domestic violence and those in chronic homelessness as medically frail.

Algorithms, not people, are driving the process for establishing medically frail in Kentucky. No appeals process. No feedback loop on the process. Try your best to open dialogue on that issue as quickly as possible.

We have expressed and shared our concerns about unofficial limits on the number of medically frail individuals. When implementation was initially started in 2018, only around 10% of Medicaid recipients were deemed “medically frail” by the algorithms and other processes. Since implementation was subsequently delayed, we’re monitoring this information and making requests for non-personal data to ensure

Get involved in defining “community engagement” in the work requirements. Does taking an online screening count for something? Taking a class offered by a local MHA affiliate or other community organization? Attending a support group?

Be aware of how and when reporting is happening. Arkansas only allowed online reporting so people without internet access, computer literacy, etc. were negatively affected. Kentucky’s requirement is to report every 10 days if income fluctuates; compliance with that will increase churn (the number of people cycling on and off Medicaid rolls) and cause additional confusion.

Have a coalition working to mitigate any harm. The more voices and the more varied the interest groups, the better you will be.

Gather and publish personal stories about the effects of these - the discussion of them, the reality of the benefits of coverage, and follow individuals after they are in effect. InsureKY used a simple Google Form survey to collect hundreds of comments and stories.

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