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The Center Submits Comments Opposing the Medicaid Waiver Proposal

Last week, The Center for Health Affairs submitted comments to the Ohio Department of Medicaid opposing their current Medicaid waiver proposal. ODM drafted the proposal, referred to as the “Group VIII Work Requirement and Community Engagement 1115 Demonstration Waiver,” per the legislative instructions of the Ohio General Assembly in enacted House Bill 49 (HB 49). HB 49 instructs the ODM director to submit an 1115 Demonstration Waiver request to the Administrator of the Centers for Medicare and Medicaid Services to change the eligibility process for the Medicaid expansion population in Ohio.

Specifically, the current Medicaid waiver proposal creates a new prerequisite for the adult Medicaid expansion population by requiring able-bodied enrollees to work or participate in a community engagement activity for a minimum of 20 hours per week, or an average of 80 hours monthly. The current proposal, available on ODM’s website, includes SNAP education and training, job search and job readiness programs, and Work Experience Programs as qualified activities under the new requirements.

Given the impact on healthcare access and delivery, The Center and its Ohio hospital members oppose the current Medicaid waiver request. In written comments, The Center highlighted a number of concerns with the current proposal, including:

Limiting access to healthcare

• Early estimates show the proposal, if enacted, would eliminate coverage for over 18,000 current enrollees. However, estimates by ODM also indicate that nearly 40,000 enrollees would be subject to an audit process that could lead to disenrollment.

• Regardless if 18,000 or 40,000 participants are disenrolled, The Center and its member hospitals believe this dramatic change in the enrollment process will ultimately disrupt healthcare delivery. Healthcare providers will continue to be tasked with providing high quality, coordinated care under a new system, which is likely to leave many without insurance.

• The current Medicaid waiver proposal also stands to increase the cost of care in a number of ways. Healthcare providers, who under current law do not turn patients away based on their ability to pay, will continue to provide care to patients regardless of their insurance status. Additionally, government agencies – ODM and local County Department of Jobs and Family Services (CDJFS) – will face a substantial increase in caseloads and administrative work, leading to increased costs.

While the state’s public comment period has closed, ODM is required to open a federal 30-day comment period prior to submitting its final Medicaid waiver request to CMS. The dates for this comment period have not yet been released.

For information on The Center’s comments or the current Medicaid waiver proposal, contact us.