UPDATE: MICHIGAN: Thank You to all who commented: 671 comments AGAINST work requirements for Medicaid!


As I've written about many times before, my home state of Michigan is, unfortunately, among the states which are trying to institute work requirements for ACA Medicaid expansion for 680,000 Michiganders. As I've also written about many times before, work requirements for Medicaid are not only burdensome and cruel, they're counterproductive in terms of efficiency, economics and even in the stated goal of such programs, which is supposedly to "inspire" low-income people to get a job.

Michigan’s Medicaid Proposal Would Harm Low-Income Workers — And Can’t Be Fixed

Specifically, the Michigan bill, or any similar proposal, would:

  • Lead to large coverage losses. If the Michigan House lowers the hours-per-week requirement, it would only make it similar to the work requirement approved in Kentucky, which projects large coverage losses....
  • Harm working Medicaid beneficiaries. The industries that commonly employ Medicaid beneficiaries — such as health care services, restaurant and food services, and construction — generally feature variable hours, above-average levels of involuntary part-time work and irregular scheduling, and minimal flexibility....
  • Harm people with disabilities and other vulnerable groups. The Michigan bill, like proposals in other states, exempts people who are medically frail or have medical conditions that prevent them from working. Still, some people with disabilities and serious illnesses would inevitably fall through the cracks and lose coverage....
  • Create new state costs. Michigan would have to spend between $20 million and $30 million a year to administer a work requirement, the Michigan Senate Fiscal Agency estimates. This estimate is mostly a function of the size of the population affected, the Fiscal Agency says, which means that the time and cost to regularly verify each person’s eligibility under the new requirements would be the same regardless of the bill’s specific requirements....

Well, the law passed anyway, and now the only thing standing in the way of it being officially implemented is the Public Comment requirement at Medicaid.Gov.

While it may seem like a futile effort, the reality is that this public comment system was a large part of the key to blocking, or at least delaying, implementation of requirements such as these. This was proven just a few months ago in Kentucky:

Federal administrators are hoping to re-approve Kentucky’s Medicaid 1115 waiver, Kentucky HEALTH, after it was recently blocked in federal court. In response to the court ruling, the Center for Medicare and Medicaid Services (CMS) is once again collecting comments on the waiver. This is an enormous opportunity for advocates to weigh in.

Comments Matter and Can Influence Approvals, Court Decisions

The court relied heavily and explicitly on federal comments in its June 29th ruling on the Kentucky HEALTH waiver, in which the judge criticized federal administrators for ignoring public comments in their decision to approve the waiver.

Comments on Kentucky’s waiver are more important than ever, and administrators need to hear from stakeholders both in Kentucky and from across the country. The waiver’s re-approval would add numerous regulations and roadblocks to the state’s Medicaid program, including work requirements and other barriers to coverage and care. It would also set dangerous precedents for other states that are implementing or even considering similar waivers. View our 50-state Medicaid waiver map.

We’ve seen just how big a difference these comments can make, and now is time to speak up.

Well, the exact same thing holds true for Michigan.

That's why I'm asking--urging--my readers to chime in with a polite-but-firm comment at Medicaid.Gov opposing work requirements for Healthy Michigan (aka our Medicaid expansion program).

It's incredibly easy to do...just go to the link, type in your comments (again, be polite but clear about why you're opposing this requirement) and click "Finish" at the bottom. That's it.

As of this writing, there are only 57 91 192 227 348 573 comments. There's only ONE WEEK FIVE FOUR THREE ONE DAY LEFT to do so (the deadline is October 26th at midnight).


UPDATE: Final tally: 671 comments, or 614 more in just one week. Not bad!

Will it make any difference? Probably not, but you never know; at least there's a chance now...