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 are being phased in for enrollees ages 30 to 49 from June through September, 2018, and for 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. Enrollees lose coverage for the rest of the calendar year after not meeting the requirements for any three months. The Arkansas Department of Human Services released data related to work requirements in June and July. This brief looks at the data for July 2018 released on August 14.
Of the 43,794 people who were subject to the new requirements in July 2018, only 844 (2%) met the work and reporting requirements. The large majority (69%) were exempt from the reporting requirement because they already were working at least 80 hours per month or met an exemption from working. The remaining 29% did not report 80 hours of qualifying work activities and are at risk for losing coverage (Figure 1).
Most of the enrollees who were exempt from the reporting requirement 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 (19%), those with a dependent child in the household (14%), and those who have been identified as medically frail (14%) (Figure 2). The shares in each of these groups were stable from June to July. These enrollees are 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.
The vast majority of the small share of enrollees meeting the work and reporting requirements were already meeting comparable SNAP requirements. Of the 844 enrollees meeting the work and reporting requirements in July, 2018, more than three out of four (76%) were doing so by meeting SNAP requirements (Figure 3). Ten percent were meeting the requirements through work, and two percent through volunteer activities. The remaining twelve 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 (205 enrollees) of those who met the work and reporting requirements in July reported doing so by working, volunteering, or another activity, other than meeting SNAP requirements (Figure 3). 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.
One in three enrollees (12,722) subject to the work and reporting requirements in July 2018 did not report 80 hours of qualifying work activities (Figure 1). Nearly all of the enrollees in this group 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 (135) did report some work activities but not 80 hours of qualifying activities. Of this group, 23 enrollees reported 80 or more hours of job search or job search training; 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. Forty-nine (49) enrollees reported activities that fell short of the 80 hour requirement, including 16 with at least 61 but less than 80 hours of work.
Overall, state data show that 5,426 enrollees have not met the work and reporting requirements for two months (Figure 4). A higher number did not meet the requirements for one month (6,531). If enrollees do not meet the requirements for any three months, they will be disenrolled and locked out of coverage for the rest of the calendar year. They could reapply for coverage in January, 2019. Individuals need to report work activities or exemptions by the 5th of the following month. So, the 5,426 enrollees who already have missed two months are at risk of losing coverage if they do not meet the 80 hour work requirement in August and do not report their August activities online by September 5. The total number of enrollees reported by the state as not meeting the requirements for one or two months (11,957) is as of August 7, 2018, and accounts for case closures that are not related to the work and reporting requirements; as a result, this total is lower than the 12,722 enrollees who did not report 80 qualifying hours for July (Figure 1).
Looking ahead to next set of data to be released from the state for August 2018, the key question will be how many enrollees will not have met the new requirements for three months and therefore will be subject to a loss of coverage and a coverage lock-out. Other questions include whether enrollees understand the new requirements and how to use the online portal; how many enrollees are newly working, and in what types of jobs, as a result of the requirements; how many enrollees will be identified as exempt and for what reasons; whether some enrollees subject to disenrollment will be found to have good cause for not meeting the requirements; and what the coverage losses and lockouts will mean for enrollees, providers, and health plans.