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In conjunction with other advocacy organizations, the Center for Medicare Advocacy submitted comments during the re-opened comment period for the Kentucky HEALTH Medicaid Section 1115 waiver demonstration application. The Center strongly believes that Kentucky HEALTH should be rejected as it will lead to substantial coverage losses. Kentucky’s proposal will take health coverage away from individuals who cannot document that they meet rigid work requirements, including those who are working or eligible for an exemption but fail to meet the paperwork requirements.

The threat of losing insurance is not a proper way to promote work among Medicaid beneficiaries. Nationally, 60 percent of non-SSI adults are already employed and working; however, most beneficiaries who work full-time still have “annual incomes . . . low enough to qualify for Medicaid.”[1] As the data indicate, these beneficiaries are employed in vital industries where they earn low wages. Many of these beneficiaries work in our nation’s hospitals, home health care services, and nursing facilities.[2]

Even Kentucky estimates that 15 percent of adult beneficiaries—97,000—will lose coverage due to these proposed requirements. [3] States with similar proposals likewise estimate a significant drop in coverage. However, studies on the impact of the Affordable Care Act’s Medicaid expansion suggest that work requirements may actually have a negative effect on a beneficiary’s ability to find or maintain employment. For instance, one study finds that 52.1 percent of beneficiaries in Ohio believe that “attaining coverage made it easier to secure and maintain employment.” Creating unnecessary barriers to health care may result in more beneficiaries losing employment opportunities, instead of gaining them.  

Medicaid expansion is proving to be a critical lifeline, allowing beneficiaries to fill important positions that might otherwise go unfilled due to low wages and the lack of health coverage. Perhaps this lifeline is why “national, multi-state, and single state studies show that states expanding Medicaid under the ACA have realized budget savings, revenue gains, and overall economic growth.”[4] Building barriers to health care coverage not only hurts Medicaid beneficiaries but also the labor market. The Center respectfully urges HHS not to approve Medicaid waivers that place unnecessary burdens on beneficiaries, the Medicaid program, and the economy.

August 23, 2018 – D. Valanejad, B. Belton

[1] Rachel Garfield and Robin Rudowitz, Understanding the Intersection of Medicaid and Work, Kaiser Family Foundation (Dec. 7, 2017),
[2] Id.
[3] Hannah Katch et al., Taking Medicaid Coverage Away From People Not Meeting Work Requirements Will Reduce Low-Income Families’ Access to Care and Worsen Health Outcomes, Center on Budget and Policy Priorities (Aug. 13, 2018),
[4] Larisa Antonisse et al., The Effects of Medicaid Expansion under the ACA: Updated Findings from a Literature Review, Kaiser Family Foundation (Mar. 28, 2018),

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