Work requirements are conditions on Medicaid eligibility for certain adults to work or participate in community engagement activities in order to maintain health benefits. As of April 1, 2019, CMS has approved Medicaid work requirement waivers for nine states. Six more are pending.
Work requirements remain controversial for several reasons. Research shows that six in ten non-elderly Medicaid adults are already working. About a third are not working due to illness, disability, caregiver responsibilities or school attendance, leaving just 7% who remain eligible for work requirements. Some argue that these statistics imply there is not much need for these policies as a condition of eligibility. Additionally, imposing barriers to coverage such as burdensome attestation requirements contributes to gaps in coverage and Medicaid member churn.
As we already see with the annual Medicaid renewal process, notices may not get to enrollees because of address changes, people may have trouble navigating web portals (one in three Medicaid enrollees reported never using a computer), and busy lives contribute to missed deadlines that result in loss of coverage.
We have seen the negative impact of these policies play out in Arkansas, the first state to implement a Medicaid work requirement in July 2018. Over 18,000 enrollees lost coverage due to noncompliance, with only 1,910 coming back onto the roles at the start of 2019. The Arkansas program requires monthly attestation. Each month that the beneficiary does not attest or meet the requirements through work or an exemption, results in a “strike.” After three strikes, the beneficiary is disenrolled from the Medicaid program for the remainder of the year. An average of 80% of those subject to the new requirements were exempt for a variety of reasons (they were employed more than 80 hours/month, had a dependent child in home, were medically frail, etc.), leaving an average of 20% that did not comply with the work requirements. Of those who did not comply, 99% did not report anything at all to the state, giving credence to the statement that additional administrative processes result in lapsed coverage. Only 2% of those required to report work status, did so each month.
While the Arkansas experience is concerning, there are ways to mitigate the unintentional negative impacts of work requirements. By providing proactive, tailored outreach to those members subject to these new policies, stakeholders such as health plans, provider groups, and state agencies are able to help their Medicaid beneficiaries avoid costly lapses in coverage.
HMS collaborated with a health plan serving the Arkansas Medicaid population to prepare for the implementation of the new work requirements. Using HMS' Eliza member engagement solution, we deployed a multi-channel, multi-touch program using automated phone, email and text message reminders to educate members about the new requirements and instruct them in how to maintain their health coverage by reporting their work activities (or exemptions) each month. We also notified members if they failed to comply in any given month, advised them on how many more “strikes” they had before losing coverage and offered support with the attestation process so members wouldn’t lose coverage for the remainder of the year.
The results were positive, with those that Eliza reached having an almost 8% higher rate of retention at the end of the year than those not reached. We found that providing members with notice of their strikes improved compliance with the monthly attestation process the following month by as much as 25%. Furthermore, 80% of members asked wanted a reminder to attest each month, with 91% requesting text messages and 55% opting for email reminders.
Work requirements are a growing trend in state Medicaid programs, and despite several legal challenges, CMS fully supports these policies. States and health plans alike will have the responsibility to educate and assist beneficiaries with complying in order to mitigate Medicaid member churn.
To learn more about how your organization can help support your Medicaid members subject to work requirements, schedule a conversation with one of our industry experts.