In a letter to HHS Secretary Alex Azar, the Medicaid and CHIP Payment and Access Commission (MACPAC) expressed concern regarding early results from Arkansas’ work and community engagement requirements and asked the administration to pause the program.
Last month, the state announced that more than 4100 Medicaid expansion enrollees would lose coverage for the rest of the year—on top of the 4353 that lost coverage in September
—for failing to report their work, volunteer, or job training activities under the requirements, which were approved in May and implemented in June. Arkansas was the third state to receive CMS approval for their work requirements and the first to implement them. The program requires those eligible between the ages of 19 and 49 years to log 80 hours a month; those who fail to do so for 3 months lose coverage for the rest of the calendar year.
Citing the low level of reporting and subsequent drop of 8462 individuals from coverage, MACPAC said that the current process is likely not structured in a way that provides enrollees an opportunity to succeed under the requirements and, as a result, is calling for a pause in disenrollments in order to make proper adjustments to the program to promote awareness, reporting, and compliance among beneficiaries.
While MACPAC credited the state with successfully using administrative data to identify exempt beneficiaries and those in compliance, as well as engaging in education and outreach activities, they noted that 91.6% of beneficiaries required to comply with the requirements failed to do so in September.
“When states make significant changes, beneficiaries should have the opportunity to learn about the changes, understand new obligations, and succeed in complying,” wrote the commission.
They added that given the short implementation time frame in the state, there is likely an absence of sufficient measures and data to interpret early results and guide adjustments, and based on past state experiences with major program innovations, more time may have been needed to develop and robust program.
“As HHS considers these proposals, it should require the development and approval of robust evaluation and monitoring plans to measure whether waivers achieve their intended purposes and provide meaningful information along the way, including during the early days of implementation,” they wrote.
In addition to beneficiaries not being aware of the requirements—as the Medicaid population has historically been hard to reach and educate—a reliance on online reporting might also be creating a barrier to successful reporting due to limited internet access in the state and the multistage process for registering an account and inputting their information, they argued.
They also noted the importance of connecting beneficiaries to job search or work supports, as well as other resources, such as transportation.