Last week, the Medicare Rights Center submitted comments to the U.S. Department of Health and Human Services (HHS) on Medicaid waiver proposals from Kentucky and Mississippi. Both states are seeking the agency’s permission to require low-income, “able-bodied” adult residents to work, volunteer, or train for a job in order to maintain their Medicaid coverage.

In both sets of comments, we express our concerns that the proposed changes would undermine access to health care for low-income people who are not yet eligible for Medicare, including older adults and people with functional limitations or chronic conditions. Such individuals may not be administratively classified as “disabled”—and therefore exempt from the work requirements—but they may nevertheless face significant health challenges that drive unemployment or underemployment.

In addition, administrative hurdles may block people who are working or who have an exception from keeping their Medicaid coverage. In Arkansas, for example, people subject to new paperwork requirements are struggling to notify the state that they are working or otherwise eligible to keep coverage.

As we discussed last month, a court case (Stewart v. Azar) blocked Kentucky from instituting their work requirements, at least temporarily. As a result, HHS reopened Kentucky’s waiver for public comment. The same day, it also reopened comments on Mississippi’s waiver, which the state recently amended and resubmitted.

The Medicare Rights Center continues to oppose efforts that seek to exploit the Medicaid program’s deference to state innovation by using the waiver process to reduce or restrict coverage. Such tactics do nothing to improve access to health care for people with Medicaid, and as such run contrary to the fundamental purpose of the program.

Read our comments on Kentucky HEALTH.

Read our comments on the Mississippi Medicaid Workforce Training Initiative.