Today, Advocates for Ohio’s Future submitted our comments and sign-on letter in response to Ohio’s proposed Medicaid work requirements waiver, which was released for public comment on December 17, 2024. The letter was signed by 49 organizations and 93 individuals across 24 counties who share AOF’s concerns.
Read the letter and the full list of signatories HERE
Dear Director Maureen Corcoran and Members of the Bureau of Health Plan Policy team:
Advocates for Ohio’s Future (AOF) is a nonprofit, nonpartisan coalition of state and local health and human services policy, advocacy and provider organizations that strive to strengthen families and communities through public funding for health, human services, and early care & education. We work to empower and support nonprofit organizations in the critical work they do, especially as it relates to lifting up the most vulnerable among us.
AOF and the undersigned organizations and individuals write in strong opposition to the Ohio Department of Medicaid’s proposed Group VIII 1115 Demonstration Waiver Application, mandated by House Bill 33 passed in the 135th General Assembly, that would create new pre-enrollment requirements for Ohioans to be employed or enrolled in school or an occupational training program prior to accessing the Medicaid program. The proposed work requirements are not aligned with the purpose of the Medicaid program, which is to provide health care coverage to low-income families and individuals.
Good health is a critical prerequisite for maintaining a job, earning an education, and participating in communities, which are in turn critical for building economic stability. The proposed waiver would reduce access to health care for low-income Ohioans eligible for Medicaid and would reduce positive health outcomes, lead to increased medical debt, and increase the cost of administering the Medicaid program.
The proposed waiver asserts that engagement in work, education, and training programs will lead to improved health outcomes for Medicaid enrollees. In actuality, the reverse is true. Improved health outcomes will likely lead to deeper community engagement, including through work, education, and training.[1] The implementation of the proposed work requirements for the Medicaid expansion population would have ripple effects across the lifespan and across health and human services sectors.
We are concerned about the impact the proposed 1115 waiver would have on the following populations:
1. Ohioans participating in the Unemployment Insurance program who lost a job through no fault of their own and are in search of a new role.
2. Ohioans with physical or behavioral health needs who haven’t been able to document or receive a diagnosis of “intensive physical health care needs” or “serious mental illness” as required by the waiver due to healthcare workforce shortages, lack of services in their geographic area, or the cost of services without Medicaid.
3. Ohioans who serve as unpaid caregivers for older Ohioans or persons with disabilities.
4. Ohioans who are already participating in public benefits programs that include work requirements, such as Ohio Works First or the Supplemental Nutrition Assistance Program, and would be forced to navigate additional, duplicative requirements if this waiver were approved.
5. Ohioans who will face medical debt if access to Medicaid is lost and no alternative insurance coverage is available to them.
6. Ohioans earning below 100 percent of the Federal Poverty Level who, if Medicaid coverage is lost, will be unable to enroll in the Affordable Care Act Marketplace due to cost-prohibitive insurance premiums and who will be ineligible for premium tax credits, but who do not have access to insurance through a family member or a job.
7. Ohioans who are survivors of domestic violence who have not yet found a job after leaving an unsafe environment.
8. Ohioans with as-yet undiagnosed disabilities who are not yet connected to Social Security Disability Insurance or other programs to support people with disabilities, and thus unable to qualify for a work requirement exemption.
9. Ohioans without access to reliable, consistent, and affordable transportation who may be unable to report for work for the required number of hours each month.
10. Ohioans who live in an area where work or education opportunities are not readily available close to home.
11. Ohioans with physical or behavioral health challenges that are not considered “severe” or “intensive” who participate in the workforce but are unable to maintain consistent employment.
12. All Ohioans enrolled in or in the process of enrolling in Medicaid, because the proposed work requirements would create additional administrative hurdles for enrollees and case workers alike.
In the application, the Ohio Department of Medicaid estimates that “no more than 61,826 individuals will be considered not exempt and not currently working.” However, a review of Census Bureau data by The Center for Community Solutions finds that 448,173 Ohioans would be at risk of losing Medicaid coverage under the new requirements.[2]
Ohio can learn from the experiences of Georgia and Arkansas, where Medicaid work requirements have led to thousands of Medicaid enrollees losing access to coverage, deferring medical care because of cost, and falling into medical debt – all while the programs showed no evidence of increased work, training, or education engagement amongst Medicaid members.[3] [4]
AOF and the undersigned organizations and individuals oppose the creation of additional barriers and administrative burdens to accessing the Medicaid program, and ask that the Department of Medicaid respond to the following questions:
1. How did the Ohio Department of Medicaid calculate the 61,826 Medicaid members who will lose access to coverage due to loss of eligibility?
2. Does the Department of Medicaid have estimates of how many Medicaid members will be disenrolled from Medicaid due to other reasons, including not receiving communication regarding the changes, difficulty navigating the new requirements due to lack of reliable internet access or low digital literacy, or those who face obstacles to verifying their exempt status?
3. How will the Department of Medicaid and the state support Medicaid enrollees who are unable to access programs through Ohio Means Jobs or Workforce Innovation and Opportunity Act (WIOA) centers, as these are not entitlement programs and face limited funding and capacity?
4. How will the Department handle applications for Ohioans who are unable to access mental and behavioral health treatment or care in their communities due to living in Health Professional Shortage Areas or due to long waitlists to access care?
5. What are the administrative cost estimates for the staffing and resources needed to verify eligibility and manage work requirements? How will the state increase funding to support counties in administering these new requirements?
Thank you for the opportunity to submit comments and questions regarding this proposal. AOF and the undersigned urge the state of Ohio to invest in programs that support Ohioans on the path to economic stability, rather than in punitive, burdensome requirements that will cause harm and restrict access to Medicaid coverage for low-income Ohioans.
Sincerely,
Advocates for Ohio’s Future
Undersigned: Review the full list of signatories HERE
[1] Larisa Antonisse and Rachel Garfield, “The Relationship Between Work and Health: Findings from a Literature Review,” KFF, August 2018, accessed at https://www.kff.org/medicaid/issue-brief/the-relationship-between-work-and-health-findings-from-a-literature-review/
[2] Campbell, E. (2025, January 13). Ohio’s proposed Medicaid work requirement could cost thousands of Ohioans their healthcare coverage. The Center for Community Solutions. https://www.communitysolutions.com/resources/ohio-medicaid-work-requirement-lose-healthcare-coverage
[3] Sommers, B. D., Chen, L., Blendon, R. J., Orav, E. J., & Epstein, A. M. (2020a). Medicaid work requirements in Arkansas: Two-year impacts on coverage, employment, and affordability of care. Health Affairs, 39(9), 1522–1530. https://doi.org/10.1377/hlthaff.2020.00538
[4] Harker, L. (2024, December 19). Georgia’s Medicaid Experiment Is the Latest to Show Work Requirements Restrict Health Care Access. The Center on Budget and Policy Priorities. https://www.cbpp.org/blog/georgias-medicaid-experiment-is-the-latest-to-show-work-requirements-restrict-health-care