Another 1,232 Arkansas Medicaid beneficiaries lost coverage on January 1 for not reporting at least 80 monthly hours of work or work-related activities for three months, bringing to 18,164 the number losing coverage since the state imposed its work requirement last June.

Even under its rigid requirement, the state didn’t have to take coverage away from this latest group. Under Arkansas’s rules, beneficiaries who lose coverage after their third month of non-compliance are locked out for the rest of the calendar year. The third month of non-compliance for the latest group losing coverage was December and, because January begins the next calendar year, they could have regained eligibility on January 1. But rather than continue their coverage, the state chose to end it, so they must reapply to regain eligibility.

Individuals in earlier groups losing coverage could have reapplied in December to regain coverage starting January 1. But fewer than 1,000 have done so. Many didn’t know they were subject to the work requirement or understand how to comply, according to reports, so they likely don’t know they can regain eligibility and how to do that. Others may struggle to navigate the application and verification process. Or, knowing that the state will likely end their coverage again after three months, some residents may be “saving” their months of eligibility for a later time when they may need it the most.

For current beneficiaries and those re-enrolling, the three-month “clock” restarted in January, so no more terminations will occur until April 1. The number of beneficiaries who risk losing their coverage, however, will continue rising as Arkansas begins applying the work requirement to beneficiaries aged 19-29; up to this point, the work requirement has applied to those aged 30-49. The inclusion of 19- to 29-year-olds will add about 45,000 beneficiaries to the 77,000 subject to the requirement in 2018, putting their coverage at risk if they can’t navigate the state’s complex rules and reporting requirements.

Although the state added a new phone reporting option on December 19 (to its online portal that beneficiaries previously had to use), the new option apparently hasn’t measurably affected compliance with the reporting requirement. In December as in past months, 4 in 5 of those required to report failed to do so.

As noted, a staggering 18,164 beneficiaries lost coverage in 2018 — that is, 23 percent of those subject to the work requirement — even though the policy didn’t take effect until June and many beneficiaries were subject to it only for a few months as Arkansas phased in the requirement from June through September. Although fewer beneficiaries lost coverage at the end of December than in previous months, that’s because so many vulnerable beneficiaries had already lost it by then. The last cohort of beneficiaries to begin facing the work requirement last year did so starting in September, and many lost coverage three months later at the end of November. Most remaining beneficiaries in the group subject to the requirement are already working or exempt from the requirement.

Arkansas’s experience should serve as a warning to other states about the human toll of taking coverage away from people who can’t meet rigid work requirements. No matter how they’re implemented, all work requirements will have unintended and harmful consequences — most notably, taking coverage away from people who are already working or should be exempt. These fundamentally flawed policies can’t be fixed.