Alabama’s proposed new Medicaid work requirement waiver would be costly, counterproductive, ineffective and harmful to thousands of families who live in deep poverty, Alabama Arise wrote in official comments submitted to state Medicaid officials on Thursday, Oct. 11, 2018.

“Threatening loss of health care in an attempt to force work efforts, without providing the supports that would make those work attempts successful, is flagrantly cruel and will result in no outcome other than poorer, more desperate and less healthy Alabama families,” Arise’s comments concluded.

Medicaid covers about 1 million Alabamians. Of that total, the waiver would target 7.5 percent of them – about 75,000 adults with extremely low incomes who qualify for Medicaid as parents or other caretaker relatives of children. Alabamians in this group are ineligible for Medicaid if their incomes exceed 18 percent of the federal poverty level (about $312 a month for a family of three).

Because Alabama has not expanded Medicaid to cover adults with incomes below the poverty level, the state’s work requirement plan would create a “work penalty, a catch-22 that forces people into the coverage gap,” Arise wrote. About 300,000 Alabamians already are caught in the coverage gap, earning too much for Medicaid but too little to qualify for federal subsidies for Marketplace plans.

Parents who work just 10 hours a week at minimum wage earn too much to qualify for Medicaid. But the state’s proposal would require them to engage in work-related activities between 20 to 35 hours a week. That would leave thousands of Alabama parents in a no-win situation: They would lose their Medicaid coverage if they don’t work – and also if they do. Of the parents who would not qualify for an exemption – about 1.7 percent of Alabama’s total Medicaid population, by the state’s estimates – virtually all of them would end up uninsured, without access to employer-provided coverage or an affordable private plan.

Alabama’s proposal does not project the state’s cost to track Medicaid enrollees’ work activities and exemptions. It also does not identify whether or how the state would invest in child care, job training, transportation and other supports that low-income parents need to get and keep work.