The following is excerpted from an attachment to a letter submitted to Governor Ivey asking that Alabama withdraw its proposed work requirement for Medicaid benefits. It was also sent to the State Medicaid Office.
The Arc of Alabama is very concerned that the policies described in the Alabama Medicaid Workforce Initiative Application for a Section 1115 Demonstration will result in thousands of low income people losing access to Medicaid and health care. The imposition of work requirements and the reduction from 12 months to 6 months of the Transitional Medical Assistance are harmful to parents and caretakers and establish a dangerous precedent in the Medicaid program.
The demonstration proposes that people with disabilities will be exempt but converting such a statement into an effective policy process is complicated, expensive, and fundamentally flawed. The Social Security definition for disability is quite strict (nationally, fewer than 4 in 10 applicants are awarded benefits after all levels of appeal) and denies thousands of low-income people with seriously compromised health or functional status. Consequently, many Americans with disabilities become eligible for Medicaid on a basis other than Supplemental Security Income (SSI) disability. Additional exemptions and medical frailty screens will not be enough to shield all of them from mandatory work requirements. Asking on an application if someone has a disability misses people who may not define themselves as having a disability or may not understand its importance for their eligibility. Checking claims is retrospective and often inadequate. Survey screens face similar challenges and are costly and difficult to design, test and implement.
Alabama’s application does not include an adequate description of its disability screening process including how people would be identified and provided notice that their disability, or their role caring for a person with a disability, would create an exemption to the work requirements policy. Whatever the state designs, it will mean people will have to make an appointment for a screening, or get a document signed by a doctor, or complete some other verification requirement to maintain their coverage. Others will be subjected to the work requirement, without recognition of their need for employment supports and will likely have coverage suspended. In other programs that have implemented work requirements, participants with physical and mental health issues were more likely to be sanctioned for not completing the work requirement. Even when there is an explicit exemption for individuals unable to comply due to health conditions; in practice, those exemption processes have failed, leaving individuals with disabilities more likely than other individuals to lose benefits. Inevitably, the added verification red tape will lead to coverage losses for individuals with disabilities and their families whose well-being literally depends on steady access to Medicaid supports and services.
In the end, less health coverage under Medicaid will mean worse health and less work for people with disabilities. Many people with serious health conditions require access to health care services to maintain their health and function. Requiring individuals to work to qualify would create a situation in which people cannot access the services they need to work without working — setting an impossible standard. Instead, for many it will trigger a downward spiral of health insurance coverage losses, worse health, rising out of pocket medical costs and reduced economic security.
The coverage losses predicted by the state of Alabama would be particularly tough on people with disabilities and serious illnesses. People with disabilities often need regular medical care to manage their conditions and maintain function. For them, less coverage will mean more emergency room visits or hospitalizations, along with higher health costs.
The Arc of Alabama is very concerned that this proposal does not promote employment opportunities or seek to achieve better health outcomes for the very low-income parents and caregivers receiving Medicaid. The proposal appears to be designed solely to reduce the number of people receiving Medicaid. The Arc of Alabama urges the Administration to withdraw the Demonstration application.