‘Simply cruel’: Testimony from Alabama Arise’s Carol Gundlach against Alabama’s Medicaid work requirements plan

Arise policy analyst Carol Gundlach testified against Alabama’s proposed Medicaid work requirements waiver during a public forum on Monday, March 5, 2018, in Montgomery. Here is the full text of Gundlach’s prepared remarks:

It is important for us to recognize that the people who will be affected by this proposed policy are exclusively the parents or guardians of children, often very young children. Over 90 percent of them are women. They are among the poorest people in Alabama, with an average monthly income of less than $400 for a family of three. These poor families are an extraordinarily vulnerable population to target for the potential loss of health care assistance.

Alabama offers few supports for people transitioning to work. While the waiver request says that people will be referred to supportive services, there is no reason to expect that they will be able to actually receive these services. Subsidized child care, in particular, is a necessity for a parent who works.

In Alabama, however, subsidized child care receives no state funding. As a result, most subsidized child care subsidies serve the highest priority categories, including foster children, children receiving protective services, and children who are in families that receive TANF (Temporary Assistance for Needy Families). In September 2017, there was a waiting list of over 1,000 children and significantly more pent-up need for subsidized day care. The same could be said for other support services, including job training and public transportation, which are essential job supports.

The waiver request says that people who can’t find services like transportation or child care will be exempt. But the way this section is written is particularly confusing and unclear. The waiver request says people “compliant with JOBS are exempt.” And it says that anyone exempt or deferred from JOBS (Job Opportunities and Basic Skills) will not be required to engage in work activities. To be either participating or exempt from JOBS, though, one must be receiving TANF.

There are around 4,000 adults receiving TANF and 75,000 people in the POCR (Parents and Other Caretaker Relatives) Medicaid capacity. While it appears to be implied, the actual language of the waiver request is silent or whether any of the other 71,000 participants not receiving TANF will be deferred if they don’t have child care or transportation.

The waiver request says the Medicaid work program would be “modeled” on the JOBS program. And the proposed memorandum of understanding with DHR (the Department of Human Resources) seems to indicate that non-deferred POCRs will actually be enrolled in the JOBS program or another program administered by DHR that is very similar to JOBS.

A critical element of the JOBS program is access to emergency and job support services, including auto repair, emergency housing assistance, transportation assistance, uniforms and other needs. One of the most important supports in the JOBS program is priority access to subsidized child care without having to be placed on a waiting list.

Will POCR recipients also become eligible for these TANF/JOBS-funded services? And if so, would those auxiliary services by paid for with the already inadequate TANF block grant? If so, this waiver proposes to try to expand services now covering 3,700 people to an estimated additional 17,000 individuals, further stressing an already underfunded JOBS program and reducing assistance now reserved for TANF participants mandated to participate in JOBS.

The waiver request says “every adult in the household” would be required to participate. If this is the case, is the plan to terminate the Medicaid of a compliant or exempt Medicaid recipient if a non-recipient who lives in the same household doesn’t participate? Besides the deep unfairness of punishing the Medicaid recipient for the behavior of another household member, this policy empowers the non-recipient to use the threat of the loss of insurance to abuse and control the Medicaid recipient.

Ultimately, this waiver request raises more questions about what is being proposed than it answers. Most of the answers will apparently be found in the yet unspecified MOUs with the Department of Human Resources and the Department of Labor – MOUs that may not be available to the public before they are implemented.

We need not to overlook that the intent of this proposal is to take health insurance away from targeted women who are unable, for whatever reason, to comply with employment and training activities. The request speaks to the benefits of work for children and families, and we certainly agree that, with the right supports, families are better off when there is earned income.

But I cannot see how the loss of parental health insurance can possibly benefit children. If Mom cannot afford her asthma medicine or her insulin because her Medicaid has been discontinued, then she gets sick and can’t work, or ends up in the hospital, or doesn’t buy the food, clothing or other necessities for her children in order to buy the medicine she needs. Any of these outcomes will hurt the family and the children.

The dignity of work, and the income it produces, does of course benefit families. But to use health care as the stick to force work efforts, without providing the supports that make work attempts successful, is simply cruel and will result in no outcome other than poorer, more desperate and less healthy Alabama families.

‘Alabama’s new catch-22’: Testimony from Alabama Arise’s Kimble Forrister against Alabama’s Medicaid work requirement plan

Arise executive director Kimble Forrister testified against Alabama’s proposed Medicaid work requirements waiver during a public forum on Monday, March 5, 2018, in Montgomery. Here is the full text of Forrister’s prepared remarks:

When we compare Medicaid’s waiver proposal to DHR’s welfare reform proposal in 1996, what’s most striking is Medicaid’s lack of data. How can we analyze the target population when Medicaid can’t give us information on the adults in the POCR (Parents and Other Caretaker Relatives) population?

I learned a lot when I served on Gov. Fob James’ Welfare Reform Commission. First, we analyzed Gov. James’ unjustified claims that the AFDC program (that was Aid to Families with Dependent Children, the cash welfare program now called TANF) incentivized teen pregnancy, and that AFDC was a budget-buster. In fact, it just didn’t make sense that any woman on welfare would get pregnant just to gain an additional $29 a month in welfare benefits. And with cash welfare amounting to one-half of 1 percent of the General Fund budget, it was hardly a budget-buster.

Again today, we hear unjustified claims from our governor. Gov. Kay Ivey says she wants to save taxpayer dollars and reserve Medicaid for the people who need it most. But who needs Medicaid more than the mother who’s trying to support two kids on $312 a month or less?

Even the woman who works 10 hours a week at minimum wage makes too much to meet this standard. And if this new policy “succeeds,” and she gets a 20-hour-a-week job, she is no longer eligible for Medicaid – and that defeats the whole purpose. Her new low-wage job is unlikely to provide health coverage. Her income is unlikely to be high enough to allow her to buy coverage on the marketplace. She will be caught in Alabama’s new catch-22.

Changes like this can be game-changers – but they can change the game in a bad way. We learned it the hard way in the 1990s. Well-meaning professionals in the Family Assistance section of DHR (the Department of Human Resources) assured us that there were three kinds of people among the 26,600 adult recipients (note that this was about a third of the POCR population):

  • There were those who were only using cash welfare as a temporary program that would help them get back on their feet, and they would be back in the workforce in a three to six months. They had data to show that this was a large share of the caseload. And apparently today’s Medicaid Agency is unable to do a similar analysis of the POCR caseload.
  • At the other end of the spectrum were the hardship cases who faced extreme barriers to employment, and the professionals assured us that they would be protected from harsh consequences. They truly needed the program. We would think that these are among the 4,000 to 5,000 adults now on TANF, about a sixth of the original population.
  • The professionals assured us that a middle group – between the job-ready at one end and the hardship cases at the other – were the people who just needed a kick in the pants to get off welfare and into a job, any job, and that it was easier to move up the ladder from any job than from no job.

This analysis makes some sense, but only in the context of an understanding of the barriers: women on welfare consistently said that in order to enter the workforce, they needed four things: jobs, child care, transportation and health care.

DHR in fact made some effort in these areas. People could count on a year of Medicaid coverage and child care when they took a job, and they even got a few months of cash welfare to ease the transition to work.

But we analyzed the data from the first year of implementation and discovered that the numbers didn’t match the theory. An economist on our staff did a regression analysis and discovered that the numbers in the caseload did not line up with the numbers moving from welfare to work. Instead, the lower caseload numbers lined up with the lower number coming in the front door, not the number leaving for employment.

The reality was, these women could not overcome the challenges of child care and transportation to even go to the job interviews that were required before they could get TANF benefits. The theory – that a kick in the pants would lead to a job – did not explain the numbers. The reality, played out for thousands of women across the state, was that some our most vulnerable people – young mothers who can’t access child care and transportation – were denied the $50 a week we provide in TANF benefits.

We would urge the Alabama Medicaid Agency to take a hard look at its theories and compare the theories to the numbers. Are you actually cycling a significant number of cases through a transitional period of difficulty between jobs? If so, you probably don’t need a big increase in administrative costs to get them to work.

Medicaid’s own projections show that some 57,000 people in the POCR caseload will be exempted from work requirements. But the administrative cost of making that determination will add significantly to our famously low-overhead Medicaid budget. It won’t be so low-overhead anymore.

The group that’s left – perhaps 17,000 people who are not job-ready and not hardship cases – is the group that’s at risk of essentially being kicked while they’re down. If you can’t arrange child care and transportation to start on the path to a job, you’re not getting help. You’re getting the front door slammed in your face.

Bottom line: In a state with 18.5 percent of its people in poverty, this plan proposes to put about 1.5 percent of its people under a microscope, expecting to find about 1/3 of a percent they can move off Medicaid. Gov. Ivey is proposing to put a huge administrative effort into forcing this 1/3 of a percent of the population into jobs, with the result that a few thousand mothers might get jobs, but they surely will no longer have health care.

If Alabama seriously wants to test its ability to move people from POCR to the workforce, why not propose a one-year pilot program that offers work supports without the penalties that remove their health care?