Background
On January 28, 2025, Arkansas Governor Sarah Huckabee Sanders submitted a waiver request to the Centers for Medicare and Medicaid Services requesting the implementation of a work requirement for the state’s Medicaid expansion program, currently called Arkansas Health and Opportunity for Me (ARHOME). Read news coverage on the Governor’s announcement on the Arkansas Advocate website. And you can find documents related to and public comments on the waiver on the Arkansas Department of Human Services website.
AACF Comments During Public Hearing on Friday, February 14, 2025
Camille Richoux, Health Policy Director, Arkansas Advocates for Children and Families
Good morning, my name is Camille Richoux, and I am the health policy director at Arkansas Advocates for Children and Families. Thank you for the opportunity to provide comments regarding the proposed Pathway to Prosperity 1115 proposal. Arkansas Advocates for Children and Families (AACF) is very proud of the progress we’ve made in our state to ensure every Arkansan has access to health coverage. Because of the great success of the ARHOME program, today most adults in Arkansas have coverage and improved access to important preventative care.
While the proposal claims it has incorporated lessons from previous efforts, its core premise remains deeply flawed: it creates punitive eligibility requirements that threaten the health and well-being of thousands of Arkansans.
The waiver proposal equates long-term Medicaid enrollment with poor health outcomes, citing poverty as a risk factor. However, this logic is fundamentally flawed. Lack of insurance, not Medicaid coverage, is a well-documented risk factor for poor health.
While the proposal claims that compliance is not a condition of eligibility, suspension of coverage is functionally equivalent to termination. Suspended beneficiaries lose access to necessary healthcare services, creating significant disruptions to their health and financial stability.
Any policy that results in barring access to Medicaid services for non-compliance effectively creates a new eligibility requirement. This undermines the core objectives of the Medicaid program, which is to provide access to healthcare for low-income individuals and families.
The success coaching requirements function as the monthly reporting requirement that caused so many individuals to lose coverage in 2018. This requirement poses an even greater potential burden by forcing beneficiaries to adapt their lives around scheduling and meetings.
The “Success Coaching” component introduces vague compliance criteria that go far beyond work requirements. These criteria – namely, hours worked, education status, and income level – should be defined in the proposal in order to reduce the chance of bias and inconsistency. The proposal claims that this approach will be individualized, but it is ultimately a nontransparent, subjective algorithm to decide whether someone is “on track” and continues to receive health care benefits.
The state previously attempted implementing an algorithmic decision-making system to decide how much home-based health care patients needed. Following this change, patients saw their hours of care cut drastically. Arkansans suffered from this. People who were bedridden were left without basic hygiene. They were getting bed sores from not being turned.
Studies show that the majority of Medicaid enrollees who can work are either employed or serving as caregivers. Work requirements fail to account for the realities of many low-wage jobs, such as variable schedules, the health of the overall job market, lack of paid leave, and caregiving responsibilities. In rural parts of our state, Arkansans may struggle to find any work and the job they can take may not be “on track” per this proposal’s guidelines.
If the state is committed to addressing poverty through increasing resources, education, and workforce development in low-income Arkansans, it can do that without jeopardizing their access to health care. We can add resources to address health-related social needs, not take them away. This proposal is not the way to address health or poverty in our state. Thank you for your time and consideration of our comments.