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Let’s Untangle the Red Tape in State Medicaid Proposals

By Dee Mahan,


Summer isn’t over, but the comment periods for three critical state Medicaid proposals will end before Labor Day. Each of the proposals will mean more red tape and frustrations for families seeking health care in Alabama, New Hampshire, and Oklahoma.

Federal comments due for New Hampshire

A federal comment period for a New Hampshire waiver request is closing September 2nd. Among other things, New Hampshire is asking to add more requirements for people to enroll in the state’s Medicaid expansion—things that will make it harder for people to get Medicaid coverage, like conditioning enrollment on presentation of two paper documents proving citizenship. The state already has a work requirement approved by CMS and set to begin in January 2019 (the state is requesting an extension of that approval, which should be discussed in any comment submissions, because CMS’s approval does not change the fact that work requirements are illegal under Medicaid law).

State comment in Alabama and Oklahoma

It doesn’t end there. At the state level, Oklahoma and Alabama have opened state comment periods on proposals that would add work requirements to Medicaid in those states. We expect those requests will be sent to CMS shortly after the state comment period closes. (The Alabama comment period closes on August 30th; Oklahoma on September 3rd.)

Neither Oklahoma nor Alabama has expanded Medicaid. As bad as work requirements are for consumers’ access to health insurance in states that have expanded Medicaid, they would set up even starker choices in states that have not expanded Medicaid.

For example, the proposed program in  Alabama creates a “Catch-22” for enrollees. Those subject to the work requirement would lose Medicaid if they don’t work, but also lose coverage if they do, because meeting the required number of work hours at minimum wage would result in income exceeding Medicaid eligibility. It is a Lose-Lose situation for families. Since most employers in that states don’t provide low-wage workers or part-time workers with affordable (or any) health insurance, the program all but guarantee that people subject to the work requirement will become uninsured.

All against a backdrop of more good news about the impact of Medicaid expansion

While these states and others are taking actions that will reduce the number of people who can obtain health care coverage, other states are touting the benefits of Medicaid. They are citing more evidence showing the health and economic benefits of Medicaid expansion, and the program’s critical role in addressing the growing opioid epidemic, one of the major health issues of the day.

  • Ohio just released a report on its Medicaid expansion showing that the program has significantly cut that state’s uninsured rate and helped people get jobs.  In response to the report, on August 21, Ohio’s Governor John Kasich tweeted the following: A new report out today shows an estimated 290,000 Ohioans utilized Medicaid expansion, and then transitioned off because they got a job or a raise. Expansion has worked in Ohio,” and, “…and more found it easier to find and hold onto a job”.
  • Louisiana released a report highlighting the dramatic drop in the state’s uninsured rate since the state adopted Medicaid expansion.
  • report published in JAMA found that expanding Medicaid has enabled many people to get treatment of substance use disorders, a critical step in addressing the country’s opioid epidemic.

Federal and state officials need to hear about how Medicaid is making a difference in communities across the nation and reject efforts to reduce health insurance access for hard-working low-income consumers, making them less healthy and less financially secure.

Please file comment on waivers for New Hampshire, Alabama, and Oklahoma

We urge people to comment on New Hampshire’s waiver request. We urge advocates and others in Oklahoma, and Alabama to comment on the waiver requests in those states.

  • New Hampshire’s waiver request is available here and comment can be filed here. (Closes September 2nd )
  • Alabama’s waiver in state comment period is available here; instructions for submitting comments are in this letter. (Closes August 30th)
  • Oklahoma’s waiver in state comment period can be found here. Scroll down to the section under “August 27, 2018” for links to the waiver. Comment filing instructions are here.

Families USA’s guidelines for framing state comments can help you in comment preparation. (Closes September 3rd)