On Thursday, the Center for Medicare and Medicaid Services (CMS) sent a letter to state Medicaid programs announcing that it will provide waivers to states that wish to implement work requirements for Medicaid benefits. The letter allows the the work requirements to be targeted at "non-elderly, non-pregnant adult Medicaid beneficiaries who are eligible for Medicaid on a basis other than disability."

The letter's weak wording and limited exemptions leave room for states to impose work requirements on many people who face circumstances that make work difficult. There is no prohibition on requiring caretakers (for children, the elderly, or disabled people) or students to find employment in order to recieve coverage. And for those Medicaid recipients who would already meet work requirements, they will still be burdened with yet another load of drudgery—more paperwork, record-keeping, audits, interactions with bureaucrats.

Employment Status of Medicaid Recipients, Age 18 to 64 IPUMS-USA 2011-2015

But at least the letter exempts those with disabilities, right? Not quite. It only excludes those who qualify for Medicaid on a disability basis. Essentially, if you've been determined by the Social Security Administration to be totally disabled and are recieving Supplemental Security Income (SSI) related to your disability, you are also enrolled in Medicaid (often automatically). But many disabled people who depend on Medicaid are not enrolled in this way. Qualifying for SSI Disability requires a high standard: proof of total disability that prevents gainful employment. People with a partial disability or short-term (less than a year) disability qualify for nothing, and if they need Medicaid, must qualify based on income and assets like everyone else.

Of 24.5 million adults under age 65 on Medicaid, 8 million have a disability, but only 3.8 million are also recieving SSI and can be said to have qualified for Medicaid due to being totally disabled. That leaves 4.2 million adults with disabilities (detailed below) unprotected by the language of this letter.

Medicaid Recipients with Disabilities, Age 18 to 64 IPUMS-USA 2011-2015

The most common disabilities of Medicaid recipients relate to cognition (memory and concentration), walking, and independent living (ability to run errands alone). Others cite conditions that inhibit self-care, vision, and hearing.

Medicaid Recipients: Most Common Disability Types, Age 18 to 64 IPUMS-USA 2011-2015

The letter doesn't prevent states from exempting disabled people from work requirements using a broader definition of disability. But even if states choose to do so, it will still take additional time and resources to meet those requirements, and it's inevitable that some disabled people will fall through the cracks in the determination process. For impoverished and struggling families, the addition of work requirements will at least be a reminder that their healthcare can be taken away from them whenever government bureaucrats decide they haven't earned it.

Data Source

Steven Ruggles, J. Trent Alexander, Katie Genadek, Ronald Goeken, Matthew B. Schroeder, and Matthew Sobek. Integrated Public Use Microdata Series: Version 5.0 [Machine-readable database]. Minneapolis, MN: Minnesota Population Center [producer and distributor], 2010.

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