Arkansas is one of four states for which CMS has approved a Section 1115 waiver to condition Medicaid eligibility on meeting work and reporting requirements and the first state to implement this type of waiver. CMS approved Arkansas’ waiver on March 5, 2018, and the new requirements took effect for the initial group of beneficiaries on June 1, 2018. The requirements were phased in for enrollees ages 30 to 49 from June through September, 2018, and will apply to those ages 19 to 29 in 2019. Unless exempt, enrollees must engage in 80 hours of work or other qualifying activities each month and must report their work or exemption status using an online portal. Individuals need to report work activities or exemptions by the 5th of the following month.
The Arkansas Department of Human Services has released monthly data related to the new requirements beginning in June. September was the first month that enrollees could lose coverage for failure to meet the new requirements for three months, and nearly 8,500 people have been disenrolled to date. Among the population subject to the new requirements, the shares of those exempt from reporting, not reporting, and using the portal to report monthly activities have remained consistent since June. This brief looks at the data for September 2018, released on October 15, 2018. A separate case study looks at early implementation of the new requirements.
How many individuals have lost coverage due to the work and reporting requirements?
A total of 8,462 individuals have lost coverage to date due to non-compliance with the work and reporting requirements. (Figure 1). This includes 4,353 individuals whose cases were closed in September, and another 4,109 whose cases were closed in October, as of October 8th. Under the waiver, enrollees lose coverage for the rest of the calendar year after not meeting the requirements for any three months and are barred from reapplying for coverage until the following January. As of October 8th, another 4,841 individuals had two months of non-compliance and could be at risk for losing coverage if they fail to report qualifying work activities for another month. The state data show that 7,748 enrollees did not meet the work and reporting requirements for one month as of October 8, 2018.
Few individuals have been found to have good cause for failing to meet the work and reporting requirements to date. Individuals who fail to complete 80 hours of qualifying work activities and/or fail to timely report their activities each month can request a good cause exception. The state reviewed 246 good cause exception requests in September; of these, 140 were granted. For August, the state reviewed 55 good cause exception requests and granted 45. While still relatively small compared to the number of enrollees who lost coverage, the number of good cause requests in September may have been higher than those in August, at least in part because the state experienced technical issues with the online portal in September.
How many did not report work activities for September?
Of the 73,266 people who were subject to the new requirements in September 2018, 23% (or 16,757 people) did not report 80 hours of qualifying work activities (Figure 2). Nearly all of those 16,757 enrollees did not report any work activities. This could mean that they did not create and link the online accounts required to enable them to report or experienced difficulty accessing or navigating the online portal. A small number of enrollees (222 out of the 16,757) did report some work activities but not 80 hours of qualifying activities for September. Of those 222 enrollees, 31 reported 80 or more hours of job search; however, in each month, enrollees are only able to count 39 hours of job search or job search training toward the required 80 hours of qualifying work activities, which means that those engaged in job search or job search training also must complete 41 hours of another qualifying activity or activities to meet the monthly requirement. Sixty-nine (69) enrollees out of the 222 reported work that fell short of the 80 hour requirement in September, including 20 with at least 61 but less than 80 hours of work.
How many enrollees were exempt from the new requirements and why?
The large majority (72%, or 54,977 people) were exempt from the reporting requirement for September 2018. Most of these enrollees fell into four categories: those who were already working at least 80 hours per month (46%), followed by those currently meeting or exempt from SNAP employment and training requirements (18%), those with a dependent child in the household (13%), and those who have been identified as medically frail (15%) (Figure 3). The shares in each of these groups were stable from June through September. The vast majority of the exempt enrollees (96%, or 52,714) were identified through a data match conducted by the state and therefore do not have to report their monthly work hours or exemption status using the online portal. They should have received a notice indicating that they were subject to the work requirement, but exempt from the reporting requirement. Another 4% (2,263) of the exempt enrollees were not identified through data matching but instead reported an exemption since receiving notice.
How many enrollees met the work and reporting requirements and through what activities?
Only 1,532 (2%) met the work and reporting requirements, and compliance was largely attributable to meeting comparable SNAP requirements in September 2018. This pattern also has been consistent since June. Of the 1,532 enrollees meeting the work and reporting requirements in September, more than two out of three (67%) were doing so by meeting SNAP requirements (Figure 4). It is not clear why these individuals are not part of the larger group identified by the state data match (described above) and exempt from reporting. Fifteen percent were meeting the requirements through work, and three percent through volunteer activities. The remaining 15 percent were meeting the requirements through a combination of activities that include work, volunteer activities, education and training, job search, and/or job search training.
A small number (507 enrollees) of those who met the work and reporting requirements in September reported doing so by working, volunteering, or another activity, other than meeting SNAP requirements. In August, 390 enrollees met the work and reporting requirements though an activity other than SNAP compliance. The data do not indicate whether these enrollees started working as a result of the new requirements. They already could have been engaged in work or another activity, but the state did not have this information. This is a small share of enrollees compared to the 8,462 people who have lost Medicaid coverage to date due to failure to comply with work or reporting requirements. (Figure 5)
What will future data reporting and research show?
Looking ahead, it would be helpful to understand more about the group of enrollees who lost coverage. An early look at implementation found that many enrollees have not been successfully contacted about the new requirements, despite substantial outreach and education efforts, and concern that many who remain eligible could lose coverage for failure to navigate the process to verify work status or qualify for an exemption. Follow-up with individuals subject to the new requirements will provide additional information about whether individuals understand the new requirements and how to use the online portal and whether there are computer or internet access issues; how many have other health insurance coverage and how many are uninsured; how many are newly working, and in what types of jobs; how many might have been eligible for an exemption but did not apply; and whether some subject to disenrollment will be found to have good cause for not meeting the requirements. Early implementation findings also cite the potential that coverage losses will result in gaps in care and increased uncompensated care costs. Additional research can examine the longer-term effects of coverage losses and lock-outs for enrollees, providers, and health plans.