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Last week, the Centers for Medicare & Medicaid Services (CMS) reached a new low by approving South Carolina’s request to impose work reporting requirements in its Medicaid program. In doing so, the state will become the first to impose work reporting requirements primarily on low-income parents and caretakers. It will also become the second Medicaid non-expansion state to have work requirements approved, after Wisconsin. Putting parents and caregivers in the position of losing coverage if they fail to meet a paperwork requirement represents a new low in the administration’s quest to weaken and undermine the Medicaid program.
This approval is particularly alarming not only because it puts parents and caregivers at risk of losing coverage, but by doing so, it puts kids at risk of losing coverage, as well. A child’s well-being is inseparable from their parents’ and families’ well-being. Therefore, when parents lose coverage, their children are more at risk of losing coverage, too. Children rely on healthy parents and caregivers to help them stay healthy and grow, and South Carolina’s new policy will only make it harder for parents to be there for their children. Moreover, the approval will further exacerbate health, gender and racial inequities in the state, since most of the parents currently enrolled in South Carolina’s Medicaid program are women and African-American. Approving a work reporting requirement that disproportionately harms children and women of color as well as furthers structural racism represents the nadir of the Trump administration’s approach towards these proposals.
South Carolina also gives with one hand but then automatically takes away with the other in this proposal. The state will only partially expand its Medicaid program to parents and caretakers with incomes up to 100 percent of the federal poverty level, as well as certain adults who are homeless, in need of substance use disorder treatment or are involved with the criminal justice system. These new policies are expected to cover only 45,000 individuals, a number that falls dramatically short of the over 200,000 individuals who would be covered if the state fully expanded its Medicaid program. Not only that, but by imposing work reporting requirements on these newly-covered populations, the state will automatically make it harder to gain and maintain the very coverage it is now offering. In fact, by its own estimates, the state projects that thousands of parents and caretakers will lose coverage, illustrating how these paltry coverage expansions are merely fig leaves intended to mask the harms these policies will inevitably cause.
The Trump administration’s continued of approval work reporting requirements - despite the fact that recent legal challenges have halted their implementation in several states - shows how truly hell-bent it is on sabotaging the Medicaid program. While CMS Administrator Seema Verma touts work reporting requirements as a way to “lift South Carolinians out of poverty,” in reality they are an ineffective, immensely expensive policy that will only cause individuals to lose access to the care they need and states to spend money on implementing a policy that might get struck down in litigation down the road.
Have the administration’s approvals of Medicaid work reporting requirements hit rock bottom? Unfortunately, not quite yet. The health care advocacy community is particularly concerned that the next move CMS will make will be an even worse one. Specifically, CMS could approve a request to impose work reporting requirements from a non-expansion state with a significant coverage gap, such as Alabama or Mississippi. In most of those states, the income eligibility limit is so low that if work reporting requirements were approved, individuals in those states would actually become over-income if they were to meet the reporting requirement. In other words, they would be placed in an unjust “catch-22” in which they would lose coverage for both meeting and not meeting the work requirement. We hope that CMS will stop going down this dangerous path, but if past behavior is the best predictor of future actions, we’re not holding our breath.