New Hampshire Legal Assistance

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Center on Budget and Public Policy: NH Medicaid Work Requirements "harsher than Arkansas"

Posted Dec 03, 2018

Today, the non-partisan Center on Budget and Policy Priorities released a policy analysis of New Hampshire's recently approved Medicaid waiver allowing the implementation of a work requirement for certain people.


"With federal approval now in hand, New Hampshire appears poised to move forward with a new policy to take away Medicaid coverage from people not working or engaged in qualifying work activities for 100 hours per month — despite mounting evidence that it will lead thousands of residents to lose coverage, including working people and people with serious health needs," wrote Senior Policy Analyst Jessica Schubel. 

Schubel continued:

In Arkansas, the first state to implement Medicaid work requirements, over 12,000 beneficiaries have already lost Medicaid and likely become uninsured in just the first six months. In fact, the number of Arkansans losing Medicaid coverage exceeds the policy’s presumed target population — namely, people who are neither working nor qualify for an exemption — so working people and people who should be eligible for exemptions are almost certainly losing Medicaid. News accounts confirm that the policy is having severe unintended consequences — including working people losing their jobs because they fail to meet complex reporting requirements, in turn losing their Medicaid, and then being unable to get treatment for chronic conditions that’s necessary for them to work...

Yet the New Hampshire policy that the Administration just approved is even harsher than Arkansas’, in several ways:

  • Its 100-hour threshold exceeds the 80 hours that Arkansas and most other states proposing these policies require.
  • It applies to adults up to age 64, versus 49 in Arkansas; older adults are less likely to be working, in part because they’re likelier to face serious health challenges.
  • It applies to parents of children age 6 and older, whereas Arkansas’ policy excludes parents. Eliminating parents’ coverage harms children because families lose financial security and parents are less able to take care of their own physical and mental health. Studies also find that children are likelier to have health coverage when their parents do, too: children’s coverage and access to care both improved as states expanded Medicaid coverage for parents.

Also, the policy CMS approved goes beyond New Hampshire’s revised waiver application in that, starting in May 2020, it doesn’t allow beneficiaries to maintain their coverage if they need more than one month to make up missed hours from a previous month.

As we’ve explained, many of those who will likely lose coverage due to New Hampshire’s waiver will be working people who can’t meet the 100-hour requirement every month, and others who should be exempt but can’t overcome the red tape to prove it...

Since New Hampshire adopted the Affordable Care Act’s Medicaid expansion, its uninsured rate has fallen by 45 percent, and the share of adults forgoing care due to costs has fallen by about a quarter. Medicaid is now an important source of coverage for over 52,000 low-income adults in New Hampshire, providing cervical, breast, and colorectal cancer screenings to over 20,000 adults and substance use disorder services — which are critical in combatting the opioid epidemic gripping the state — to 11,000 adults. And uncompensated care costs have fallen by about half as a share of hospital budgets since expansion took effect. New Hampshire should reconsider moving forward with its harmful changes or risk joining Arkansas in seeing thousands of low-income adults lose coverage, reversing the state’s recent progress.

As NHLA Policy Director Dawn McKinney stated on Friday when the waiver was approved, "77% of people on Medicaid in New Hampshire are in working families.  Those who aren’t working are sick, disabled, or taking care of family.” 

The Center also showed last month that Medicaid work requirements fail to protect people who don't work because of a disability. Click here to read that policy analysis.