By Michaela Gibson Morris

TUPELO – A reopened public comment period for a proposed Medicaid work requirement drew more than 300 comments.

The revised Medicaid Workforce Training Initiative Demonstration Waiver focuses on a small group of working age adults on the Mississippi Medicaid rolls. Through Aug. 18, there were 347 items recorded in the public comment section on Medicaid.gov. The responses were overwhelmingly opposed. Respondents could choose to identify themselves or not in the publicly viewable comments.

“Despite the name, this seems like a paltry way to save the state a few dollars at the expense of too many Mississippians…I am unclear what I as a Mississippian gain from this initiative, and it appears my fellow Mississippians will lose too much,” one commenter, identified as C. Wall, wrote.

The Division of Medicaid views the waiver as an attempt to try something new to help Mississippians mired in poverty and poor health.

“The waiver is not designed to be a barrier to care,” a Medicaid spokesman said in written responses to Daily Journal questions. “Our intent is that promoting job training or other community engagement activities will foster improved mental, physical and emotional health and further the Medicaid mission.”

The waiver exempts children under 19, pregnant women, the disabled and those over 65 from work requirements. It primarily affects very poor parents and caregivers of other Medicaid recipients, about 57,000 of its 750,000 Mississippi Medicaid beneficiaries. Within that group, parents of children under 6, students, caregivers for the disabled and mentally ill, those diagnosed with mental illness and those in treatment for addiction or cancer would be exempted.

Those making public comments said the waiver doesn’t address the issues that would make it difficult for poor families juggling caregiving duties.

“Through work I’ve done in the Mississippi Delta, I’ve had the opportunity to meet poor families who face true barriers to accessing childcare, jobs, and transportation,” wrote a respondent who identified as a former Mississippi resident, University of Mississippi graduate and a healthy policy analyst. ”Many people do not and cannot afford a car and thus are unable to get to jobs that are located a 30-45 minute drive from their homes in rural Mississippi.”

Many of the commenters pointed to Mississippi’s low eligibility threshold for parents and caregivers of Medicaid recipients. Twenty hours a week at minimum wage would put Medicaid recipients above the income limits but well shy of the income needed to access subsidies in the federal health insurance exchange.

“I believe a work initiative is a valid requirement only if you are paying the participants a decent living wage,” wrote one respondent who did not include a name in the viewable comments. “Since minimum wage is at $7.25, the proposal is not feasible and will cause more harm than good to poverty stricken families.”

The revised waiver includes an extension of transitional medical assistance for those whose income rises while they are meeting the requirements. Currently, 12 months of transitional medical assistance is available to any Medicaid beneficiaries if their income level rises.

“The idea is TMA is available to help them transition to other forms of health insurance,” the Medicaid spokesman said. “For workforce waiver participants, if their income levels increase they get 12 months of TMA and then an additional 12 months of coverage, so they would get two years to transition to other forms of insurance.”

The Centers for Medicare and Medicaid has granted work requirement waivers in other states, but all of those states expanded Medicaid under the Affordable Care Act. Mississippi would be the the first non-expansion state to receive a waiver.

Even with the extension period, the Baltimore-based Center for Law and Social Policy filed its opposition citing a “dramatic and negative impact on access to care for deeply poor parents.”

“The state’s own estimate is that in the first year of the waiver, nearly 5,000 fewer people would be covered under Medicaid each month, and this is likely an underestimate. There is no reason to believe that these people will be transitioning to employer-sponsored insurance or earning enough to qualify for subsidies under the Affordable Care Act,” the center’s letter said.

If the Centers for Medicare and Medicaid approves Mississippi’s waiver request, the comments could still come into play. At a July forum in Tupelo (read previous coverage here), public health advocates said public comments were cited in the decision overturning Kentucky’s work requirement program.