{"id":17161,"date":"2018-11-06T03:48:15","date_gmt":"2018-11-06T03:48:15","guid":{"rendered":"http:\/\/arknews.org\/?p=17161"},"modified":"2018-11-06T15:04:34","modified_gmt":"2018-11-06T15:04:34","slug":"is-arkansas-works-working","status":"publish","type":"post","link":"https:\/\/arknews.org\/index.php\/2018\/11\/06\/is-arkansas-works-working\/","title":{"rendered":"Is Arkansas’s work requirement rule working?"},"content":{"rendered":"
\"\"
TRY AGAIN: The CMS, led by Seema Verma, wants Arkansas to redo its work evaluation plan.<\/figcaption><\/figure>\n

 <\/p>\n

Operating on the theory that employment fosters personal independence and better health outcomes, the Arkansas Department of Human Services now requires that certain nonelderly adults who receive Medicaid benefits must report their work hours to the state. The Arkansas DHS, in turn, is required to show the federal agency overseeing Medicaid that its theory is working. Under the terms of the state\u2019s agreement with the federal Centers for Medicare and Medicaid Services, the DHS must commission an independent evaluation to measure whether the policy meets its goals in the years ahead.<\/p>\n

But, although the work requirement started June 1, the state has yet to begin searching for an evaluator, in part because the CMS has yet to approve Arkansas\u2019s draft evaluation design<\/a>.<\/p>\n

On Nov. 1, the CMS sent Arkansas a letter<\/a> saying the state\u2019s proposed evaluation design \u201cshould be better articulated and strengthened\u201d in a variety of areas and requesting revisions. The CMS said the state\u2019s proposed \u201cevaluation outcomes are not well defined and outcome measures are not specified,\u201d among other flaws. That means Arkansas is likely many months away from beginning to evaluate the work requirement policy, despite the fact that it has terminated coverage for at least 8,500 Medicaid beneficiaries in the last two months alone.<\/p>\n

In mid-October, DHS spokeswoman Amy Webb said by email that the state submitted its draft evaluation design to the CMS in May and revised it in August. \u201cSince it is still under review with CMS, [a request for proposal] has not been issued for the work and community engagement requirement. DHS is in the process of developing a procurement based on the proposed evaluation plan, pending final CMS final approval,\u201d Webb wrote.<\/p>\n

The DHS provided the Arkansas Nonprofit News Network with the draft evaluation design upon request in October. (Since then, it has been made public on Medicaid.gov<\/a>.) Judy Solomon, a senior fellow at the progressive-leaning Center for Budget and Policy Priorities in Washington, D.C., said Arkansas\u2019s draft appeared to \u201cfall short\u201d in a number of ways.<\/p>\n

\u201cI\u2019m kind of not surprised that it hasn\u2019t been approved, because despite my disagreement with CMS [under] the Trump administration allowing these [work requirements], they do seem to at least have some seriousness about \u2026 having evaluations that make sense,\u201d Solomon said.<\/p>\n

Arkansas\u2019s first-in-the-nation work rule requires certain beneficiaries ages 19-49 who are on Arkansas Works, the state\u2019s Medicaid expansion program for low-income adults, to report 80 hours of work activities each month, report an exemption or lose their insurance. Most people within that age range \u2014 such as parents with dependent children in the home \u2014 qualify for an exemption. School hours count toward the requirement, as do a limited amount of volunteer and job search hours.<\/p>\n

The DHS terminated coverage for approximately 8,500 nonelderly adults in September and October who were noncompliant for three months. That doesn\u2019t necessarily mean those 8,500 people weren\u2019t working or attending school \u2014 just that they didn\u2019t report their work hours to the DHS through an online portal. Both DHS data and independent research show the majority of Medicaid expansion beneficiaries are already working.<\/p>\n

If a beneficiary\u2019s coverage is terminated, he or she is locked out of Arkansas Works for the rest of the calendar year.<\/p>\n

The work requirement has sparked vigorous debate. Are people who have lost their Arkansas Works insurance finding coverage elsewhere \u2014 such as with an employer \u2014 or are they simply remaining uninsured? Does a work requirement incentivize employment and lead to better health outcomes or does it arbitrarily punish the poor and make them less healthy?<\/p>\n

Such questions are more than academic, because the policy is by definition an experiment. It was created under a type of federal waiver issued by the CMS \u2014 known as a Section 1115 demonstration \u2014 that is intended to foster state-level innovations in Medicaid. The terms and conditions attached to the waiver amendment that created the work requirement say Arkansas must contract with an independent entity to evaluate the program.<\/p>\n

Although work requirements are sometimes attached to programs such as welfare or food stamps, no other state has imposed such a rule on Medicaid coverage. (A work requirement in Kentucky was blocked by a federal judge earlier this year, and a group of plaintiffs in Arkansas have filed suit on similar grounds.)<\/p>\n

On March 5, CMS Director Seema Verma granted Arkansas its requested waiver amendment. The federal agency told Arkansas DHS Director Cindy Gillespie in a letter<\/a> that the DHS must \u201ctest whether coupling the requirement for certain beneficiaries to engage in and report work or other community engagement activities with meaningful incentives to encourage compliance will lead to improved health outcomes and greater independence.\u201d In its rationale for allowing Arkansas to proceed with the work requirement, the CMS said the program was \u201clikely to assist in improving health outcomes\u201d because employment is \u201ccorrelated with improved health and wellness.\u201d<\/p>\n

But the draft evaluation design that the Arkansas DHS submitted to the CMS did not propose testing the hypothesis that the policy would improve health outcomes. Instead, it says, the evaluation will address \u201cthree core questions\u201d: Whether or not work requirements \u201cpromote personal responsibility and work,\u201d \u201cencourage movement up the economic ladder\u201d and \u201cfacilitate transitions\u201d from Medicaid to other types of insurance.<\/p>\n

The work requirement will \u201cresemble an income security program\u201d and should be evaluated as such, the draft design says. The state\u2019s RFP will be limited to bidders who \u201chave demonstrated experience in evaluating the impact of work requirements on participation in income security programs.\u201d<\/p>\n

Solomon said Arkansas\u2019s draft \u201c[doesn\u2019t] even raise the question of, \u2018Well, maybe if we\u2019re taking coverage away from people, it\u2019s going to make them less able to work, or it\u2019s going to make them less healthy.\u2019 \u2026 Why are they looking at this like it\u2019s not a health program?\u201d<\/p>\n

The Nov. 1 letter from the CMS raised similar concerns about the state\u2019s lack of a plan to assess what happens to people who lose coverage. \u201cIs disenrollment for noncompliance with community engagement requirements \u2026 associated with poorer health outcomes?\u201d the letter asked. The CMS suggested that Arkansas should specify measures that \u201cshould capture important features of expected outcomes such as increased employment \u2026 and improved health (e.g.: self-reported physical\/mental health, other measures of health care utilization).\u201d<\/p>\n

Asked in October why health outcomes were not the focus of the DHS\u2019 proposed experimental design, Webb responded by email. \u201cIt is widely recognized that employment improves an individual\u2019s health: Work has a positive influence on an individual\u2019s health and security; Returning to work has significant health benefits, especially mental health benefits. \u2026 People who work live longer and healthier lives,\u201d she wrote.<\/p>\n

She also said the evaluation would survey former beneficiaries who lost coverage and remained uninsured. \u201cThe survey will include relevant questions from the National Health Insurance Survey such as an individual\u2019s regular source of care, whether an individual did not receive care because of an inability to pay, and their self-evaluation of their health condition, etc.,\u201d Webb wrote.<\/p>\n

Solomon noted that the draft evaluation design only proposes looking at the estimated 69,000 Arkansas Works beneficiaries who were not initially exempt from the work requirement. That\u2019s \u201ca very short-sighted way of doing things,\u201d she said, considering many people move in and out of work.<\/p>\n

The Nov. 1 letter from the CMS noted the same issue: \u201cThe draft evaluation design does not include any discussion of [exempt] comparison groups.\u201d The letter also urged the state to develop a longitudinal survey to track former beneficiaries \u201cfor several years\u201d so as to \u201cunderstand employment, income, health status, and coverage transitions over time.\u201d<\/p>\n

Solomon said her biggest concern about the evaluation was timing, considering thousands of Arkansans were losing coverage every month.<\/p>\n

\u201cWhere is the RFP? \u2026 If you don\u2019t have a final plan and you have people losing coverage left and right, how are you going to get baseline data?\u201d she asked.<\/p>\n

MaryBeth Musumeci, an associate director at the Kaiser Family Foundation\u2019s Program on Medicaid and the Uninsured, said states with 1115 demonstration waivers often submit their evaluation designs after the fact. That may not be ideal from a research perspective, but it\u2019s \u201cnot uncommon\u201d in the Medicaid world, she said. However, the coverage losses in Arkansas make evaluation particularly urgent.<\/p>\n

\u201cI think the concern particularly about what\u2019s going on in Arkansas is because of the disenrollment that\u2019s occurred in the last couple months. ... 8,500 people having lost coverage, and not having, as far as the public knows, an evaluation plan in place,\u201d Musumeci said.<\/p>\n

This reporting is made possible in part by a yearlong fellowship sponsored by the Association of Health Care Journalists and supported by The Commonwealth Fund. It is published here courtesy of the Arkansas Nonprofit News Network, an independent, nonpartisan project dedicated to producing journalism that matters to Arkansans. Find out more at arknews.org.<\/em><\/p>\n","protected":false},"excerpt":{"rendered":"

Federal Medicaid agency says Arkansas needs better plan to evaluate work requirement.<\/p>\n","protected":false},"author":2,"featured_media":17105,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[111],"tags":[],"class_list":["post-17161","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-health-care"],"yoast_head":"\nIs Arkansas's work requirement rule working? - Arkansas Nonprofit News Network<\/title>\n<meta name=\"robots\" content=\"index, follow, max-snippet:-1, max-image-preview:large, max-video-preview:-1\" \/>\n<link rel=\"canonical\" href=\"https:\/\/arknews.org\/index.php\/2018\/11\/06\/is-arkansas-works-working\/\" \/>\n<meta property=\"og:locale\" content=\"en_US\" \/>\n<meta property=\"og:type\" content=\"article\" \/>\n<meta property=\"og:title\" content=\"Is Arkansas's work requirement rule working? - Arkansas Nonprofit News Network\" \/>\n<meta property=\"og:description\" content=\"Federal Medicaid agency says Arkansas needs better plan to evaluate work requirement.\" \/>\n<meta property=\"og:url\" content=\"https:\/\/arknews.org\/index.php\/2018\/11\/06\/is-arkansas-works-working\/\" \/>\n<meta property=\"og:site_name\" content=\"Arkansas Nonprofit News Network\" \/>\n<meta property=\"article:published_time\" content=\"2018-11-06T03:48:15+00:00\" \/>\n<meta property=\"article:modified_time\" content=\"2018-11-06T15:04:34+00:00\" \/>\n<meta property=\"og:image\" content=\"http:\/\/arknews.org\/wp-content\/uploads\/2018\/11\/seema_verma-1170x775.jpg\" \/>\n\t<meta property=\"og:image:width\" content=\"1170\" \/>\n\t<meta property=\"og:image:height\" content=\"775\" \/>\n<meta name=\"twitter:card\" content=\"summary_large_image\" \/>\n<meta name=\"twitter:creator\" content=\"@Lindsey_millar\" \/>\n<meta name=\"twitter:label1\" content=\"Written by\" \/>\n\t<meta name=\"twitter:data1\" content=\"Lindsey Millar\" \/>\n\t<meta name=\"twitter:label2\" content=\"Est. reading time\" \/>\n\t<meta name=\"twitter:data2\" content=\"8 minutes\" \/>\n<script type=\"application\/ld+json\" class=\"yoast-schema-graph\">{\"@context\":\"https:\/\/schema.org\",\"@graph\":[{\"@type\":\"Organization\",\"@id\":\"https:\/\/arknews.org\/#organization\",\"name\":\"Arkansas Nonprofit News Network\",\"url\":\"https:\/\/arknews.org\/\",\"sameAs\":[],\"logo\":{\"@type\":\"ImageObject\",\"@id\":\"https:\/\/arknews.org\/#logo\",\"inLanguage\":\"en-US\",\"url\":\"https:\/\/arknews.org\/wp-content\/uploads\/2021\/04\/annn_logo.png\",\"contentUrl\":\"https:\/\/arknews.org\/wp-content\/uploads\/2021\/04\/annn_logo.png\",\"width\":1200,\"height\":900,\"caption\":\"Arkansas Nonprofit News Network\"},\"image\":{\"@id\":\"https:\/\/arknews.org\/#logo\"}},{\"@type\":\"WebSite\",\"@id\":\"https:\/\/arknews.org\/#website\",\"url\":\"https:\/\/arknews.org\/\",\"name\":\"Arkansas Nonprofit News Network\",\"description\":\"\",\"publisher\":{\"@id\":\"https:\/\/arknews.org\/#organization\"},\"potentialAction\":[{\"@type\":\"SearchAction\",\"target\":{\"@type\":\"EntryPoint\",\"urlTemplate\":\"https:\/\/arknews.org\/?s={search_term_string}\"},\"query-input\":\"required name=search_term_string\"}],\"inLanguage\":\"en-US\"},{\"@type\":\"ImageObject\",\"@id\":\"https:\/\/arknews.org\/index.php\/2018\/11\/06\/is-arkansas-works-working\/#primaryimage\",\"inLanguage\":\"en-US\",\"url\":\"https:\/\/arknews.org\/wp-content\/uploads\/2018\/11\/seema_verma-1170x775.jpg\",\"contentUrl\":\"https:\/\/arknews.org\/wp-content\/uploads\/2018\/11\/seema_verma-1170x775.jpg\",\"width\":4928,\"height\":3264,\"caption\":\"TRY AGAIN: The CMS, led by Seema Verma, wants Arkansas to redo its work evaluation plan.\"},{\"@type\":\"WebPage\",\"@id\":\"https:\/\/arknews.org\/index.php\/2018\/11\/06\/is-arkansas-works-working\/#webpage\",\"url\":\"https:\/\/arknews.org\/index.php\/2018\/11\/06\/is-arkansas-works-working\/\",\"name\":\"Is Arkansas's work requirement rule working? 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