New Medicaid Work Requirements ‘Impossible' for People To Navigate

Miami Herald

22-05-2025

Medicaid work requirements, under consideration as part of the House Republicans' budget to cut federal spending, are "impossible" to navigate for those using the program, experts said.
Part of the budget mandates 80 hours of verified community engagement per month for able-bodied Medicaid recipients ages 19 to 65.
However, experts warn that the work requirements not only will see millions pushed off the program but also could lead to many struggling to understand what the new requirements mean for their working situation and how to report their work.
If you're unsure exactly what the new requirements could mean for you, you're not alone.
"Previous studies of states that have tried work requirements show that people are frequently unaware or confused about what the requirements mean and how to navigate the rules," Dr. Benjamin Sommers, a professor of medicine at Harvard Medical School in Massachusetts, told Newsweek.
Corroborating this, Julie Marie Donohue, a professor and chair in the department of health policy and management in the School of Public Health at the University of Pittsburgh, told Newsweek: "Evidence from states that have imposed work requirements shows people have difficulty navigating reporting systems, especially when there are monthly requirements.
"Medicaid work requirements can be complex for individuals to understand and for states to implement."
Even without work reporting requirements, Medicaid is a complex program to navigate and manage, as Medicaid beneficiaries face "a significant amount of administrative burden," Jamila Michener, a professor of government and public policy at Cornell University in New York, told Newsweek.
"They have to regularly recertify their eligibility, complete substantial paperwork, navigate managed care plans, coordinate their care, and adhere to a wide range of other requirements," she said, adding that was without having to additionally report work requirements.
While noting the degree and extent of burdens imposed by work reporting requirements will depend on how states design the administrative processes necessary to implement them, Michener said that "adding such requirements to the mix only makes things harder.
"Even in the best-case scenario, such requirements will lead to people who are eligible being denied benefits simply because they cannot jump over bureaucratic hurdles."
The Congressional Budget Office (CBO) predicted that millions of Americans would lose their Medicaid health coverage under the new policy to scale back the Affordable Care Act (ACA), but experts are concerned that many could also lose their coverage because of the legislation's complexity and administrative burden.
"Most of the people who will likely lose coverage will still be eligible for the program and lose their Medicaid due to red tape," Sommers said.
Published studies show that more than 90 percent of Medicaid beneficiaries are already working or have a good reason for not working, Sommers said, adding this might be having a disability, caring for a family member or being in school, to name a few.
This means that many who fulfill the requirements already could be confronted with a heavy administrative burden to prove that they are eligible for Medicaid coverage.
Difficulties with reporting work could become an issue for many for different reasons. If reporting will be done online, those who lack "consistent, reliable access to the internet will struggle to report their work," Michener said, while "people who lack adequate transportation to get to reporting agencies will struggle to report their work," if reporting has to be in person.
Those employed in "temporary, seasonal, contract-based or other jobs with less predictable, regular hours may struggle to report their work accurately or to meet the required hours," she added.
Even recipients who are exempt from the requirement, including caregivers of dependent children, people with disabilities, people who are pregnant, and others, may struggle to prove they are exempt or may not realize they are supposed to be exempt, Michener said.
"People in between jobs, doing gig work, working part-time, or who are self-employed may not know how to accurately report their work and may not know whether they remain eligible given these less traditional work arrangements.
"Work requirements are simply Medicaid cuts by another name. They serve little other purpose. There is little to know evidence that work requirements actually boost labor market participation."
Discussing what specific parts of the legislation appear to mean for different Medicaid recipients with Newsweek, Sara Rosenbaum, a professor of Health Law and Policy and founding chair of the department of Health Policy at the Milken Institute School of Public Health at George Washington University in Washington, D.C., said that when it comes to the number of hours recipients are required to work, it is important to know the 80 hours a month is not an average.
This means that a Medicaid recipient cannot complete the working requirements at 85 hours for one month and then hit 75 hours the next month, Rosenbaum said, as "no averaging" is allowed.
While the working requirements could be work, school, training or a number of other things, a recipient must complete the 80 hours each month.
Rosenbaum said that "every hour needs to be separately proved," adding that it was "impossible to ask people to piece together their lives this way."
Having to report every hour worked could be particularly difficult for those who are self-employed, Rosenbaum said.
"It is impossible for people who work on their own, do odd jobs, clean houses, do yard work, etc., unless the implementing rules allow oral estimation," she said, adding that she didn't think this would be likely.
Those who lose their work or can no longer complete the 80-hour requirement would "be obligated to report a changed circumstance since this is a condition of eligibility," Rosenbaum said.
Those in the process of getting work or looking for work are not exempt from the 80-hour requirement, she said, adding that those who are exempt must also prove their exemption every month.
"The measure is designed to do one thing-remove working-age adults from Medicaid," she said.
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