Medicaid plays a central role in the US health system. The program enables millions of people to access essential health care and long-term services and supports, and it has helped drive down the nation's uninsured rates to record lows. A recent wave of proposals, if implemented, could drastically affect the direction of this critical program, potentially leaving many people without health coverage. Federal law allows states to seek permission to "waive" Medicaid requirements in order to conduct "experimental or demonstration projects," as long as the projects are likely to further Medicaid's primary objective to provide access to health care to low-income individuals. States are using this discretion to seek waivers-- and in some cases have already received federal approval for them--that would place new conditions on receipt of Medicaid--like work and/or premium payment requirements. These and other policies states are seeking to impose could result in significant numbers of people losing Medicaid coverage and result in increased costs for states. Although recent federal court rulings have halted the implementation of work requirements in two states, Arkansas and Kentucky, the Centers for Medicare & Medicaid Services (CMS) continues to approve waivers that include potentially harmful policies--including work requirements. KEY FINDINGS. (1) Not all states applying for waivers are complying with the federal requirement to provide estimated enrollment impacts in their proposals. (2) Among states with waiver applications that include estimates of enrollment impacts, few provide detailed information to help state and federal officials, or the public, understand the basis for their enrollment projections. Consequently, it is difficult to determine whether states, the public, or the CMS have the information needed to understand the impacts of the proposals on individuals and on state budgets. (3) Because many states do not estimate how many people are likely to face challenges complying with requirements (including proving they are exempt from the requirement or are performing the required work activities), their estimates of coverage losses may be inaccurate or understated. (4) A review of relevant literature on Medicaid and other public programs affirms that current state estimates of coverage impacts of work requirements and the imposition of premiums in Medicaid are likely understated. (5) Administrative costs associated with the new waivers are important to consider. Failure to design, conduct, and adequately fund comprehensive outreach and education strategies for new waiver requirements will likely exacerbate coverage losses. CONCLUSION. Given the critical importance of Medicaid to millions of vulnerable low-income people, state waiver applications should better account for their effect on the people who rely on Medicaid coverage to meet their health care and long-term services and supports needs. Without this transparency, states risk inflicting unintended harm on individuals, their families, and possibly family caregivers.
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