Medicaid Work Requirements – Bad for Ohio

Below are the personal comments of Kathleen Gmeiner submitted to the Ohio Department of Medicaid on March 18, 2018 responding to the ODM’s request to CMS for a waiver to allow the imposition of work requirements on Medicaid Group VIII members.

 The Work Requirement will present significant difficulties to those enrollees who are working, to those who are not working and to those who claim exemptions.

Impact of Work Requirements on Those Already Working

We know that about 60% of the affected population is already working. But to qualify for Medicaid, most of these individuals are working in low wage jobs.  The low wage job market has a lot of volatility.  Employers work on tight margins, and constantly manage their workforce to keep their costs low. Someone working 20 hours one week may find the next they work 17 hours, because business is slow.  There is no guarantee this person will average 80 hours in a month. The individual has little, if any, control over the situation.  Other factors also come into play.  A worker’s child is sick and she stays home for two days to care for the child.  Sick time is limited in the low wage job market.  Are we going to force this parent to choose between keeping her Medicaid or tending to her sick child?


Impact on Those Not Working

For those not working, their continued eligibility will be more precarious.  They will be expected to get into a community engagement assignment. The terms of the waiver are that this community engagement will for the most part align with SNAP or OWF work requirement. This would require a routine level of commitment from the individual.  But here we are talking about a person who has little income. He may work sporadically, but not a usual 20 hours per week.  He can combine work with community engagement, but the structure of the community engagement does not allow for persons to “come and go” based on when they get opportunities for sporadic work, or a job interview if they are searching for work.  And work search activities as an exemption only apply for 30 days.   Think of this example:



Henry is unemployed but usually gets somewhere between 5-7 hours weekly of occasional labor, doing yard work or other odd jobs

He is assigned to community engagement and is expected to appear on Monday, Tuesday and Wednesday –7 hours each day.  Henry complies with his 7-hour work assignment.



Henry receives a call on Tuesday at 7 am that if he can show up at 9 am there is 6 hours of paid work available at $10/hour.  Henry has minimal income from odd jobs. He needs this money to pay his rent, and tries to reach the engagement project, but cannot reach them



Henry reports to his community engagement project and is told that if he doesn’t show up again he will be dismissed from the project.



Henry sought to make up the time he missed Tuesday on Thursday, but he is told that there are others scheduled for that day, and there is no place for him, and to show up on Monday per his regular schedule.



Henry makes calls to businesses that he thinks might need help, but the time he spends making those calls may or may not be counted toward his 20  hours, since there is no means to document them and it is not included in the waiver proposal that he can “mix and match” hours in the community engagement, hours at an odd job that he may or may not be able to document, and hours spent searching for work.


Within the month Henry is likely to lose his Medicaid—primarily because his top priority must be to make enough money each month to pay his rent, and he needs to follow those odd job opportunities wherever they lead him.


Impact on Those Who are Exempt


Those who are exempt also face problems in maintaining their eligibility.  It is not clear how they are to document their exemption.  If someone is exempt because she is in a program to address drug addiction, what part of the program counts?  If she is in the program as an outpatient for six weeks, full time presumably that can be documented.


But what about when she is discharged from the program.  Perhaps her children have been removed from her care due to her addiction.  She now must meet with children’s services workers, visit social service agencies to secure the food and other items she needs to create a home environment suitable for her children to return to.  She also is most likely attending a post-treatment meeting, possibly as much as every day.  Does she remain exempt while she goes to the support group every day?  Or does that count for 5-10 hours?  At a typical AA/NA meeting there is no one in charge to document her attendance, and what about the other 10-15 hours? Nowhere in the request is there provision made for a mother spending hours and days trying to pull her house back together to secure the return of her children. Recall that she is not a mother with minor children in her home at this point, because the children are not in her home.


There are many other reasons that this waiver should not be submitted as is, and those reasons have been stated by other commenters from multiple nonprofit and community-based organizations.  As stated above, I oppose this waiver because the requirement of 20 hours/week devoted to non-remunerative activity (for those not already working) is unrealistic for this population.


Thank you for this opportunity to comment