The current state operating budget (House Bill 49) requires Ohio Medicaid to seek federal approval to require Medicaid enrollees in the expansion group to work unless they are over age 55, enrolled in school or occupational training, participating in an alcohol or drug addiction treatment program, or have intensive physical health care needs or serious mental illness (RC 5166.37).
On February 16, Ohio Medicaid proposed a work requirement for Medicaid expansion enrollees on Sunday, July 1, that is based on state legislative requirements and the newly-issued Trump Administration Centers for Medicare and Medicaid Services (CMS) guidelines. Under the waiver program, about 5%, or approximately 36,000 of current Medicaid expansion enrollees, will need to comply with the work requirement to stay on Medicaid.
To comply with the work requirement, Medicaid expansion enrollees will need to demonstrate they work at least 20 hours a week or are engaged in other allowable activities, including job search, education and training, or unpaid work in certain cases. New enrollees must meet the requirement when they enroll, and current enrollees must meet the requirement during their annual eligibility renewal. Failure to meet the requirement results in termination of Medicaid benefits. Limited exceptions may be granted, for example for a family emergency or illness.
During the required comment period, the Ohio Academy of Family Physicians expressed extreme concern with the Ohio Medicaid’s decision to seek federal approval to implement this work requirement. In a letter to Ohio Department of Medicaid Director Barbara Sears, OAFP President Don Mack, MD, stated, “As primary care physicians serving on the front lines of patient care in Ohio, we know firsthand that approval of Ohio’s waiver application would be a devastating blow to progress made in providing health care coverage to Ohio’s Medicaid and other low-income populations. This waiver application, as written, threatens coverage of an estimated 36,000 adult Ohioans who now have coverage – a huge step backward in achieving the American Academy of Family Physicians’ long-standing goal of achieving health care coverage for all. This waiver, if approved, reverses gains made when Medicaid was expanded and care was improved by transitioning services from expensive hospital emergency departments to less expensive outpatient settings.”
The letter goes on to say, “We understand that many states are pursuing policies to seek to undermine Medicaid expansion provided under the Affordable Care Act (ACA). This particular step in the process to dismantle the ACA will lead to broad disenrollment of Ohioans who need health care coverage. This waiver increases administrative burdens for physicians, other health care professionals and county governmental agencies who have to implement the work requirement; thus expending more time on paperwork leaving less time for meeting human needs.”
Despite two public hearings and an extensive public comment period, Ohio Medicaid, on April 30, finalized the application and submitted it to CMS for review. The final waiver application is posted online and includes Ohio Medicaid’s response to public comments. CMS will post Ohio’s waiver application online for at least 30 days and then wait at least 45 days after submission before making a decision.
The OAFP will again submit comments focused on the fact that reducing coverage and access is not the direction we should be heading as a state or nation and asking that Ohio’s 1115 waiver application be denied.