For people with disabilities or complex medical conditions, accessing health care services is an absolutely necessary and often times incredibly stressful endeavor. Just getting the care needed to live a healthy and productive life can involve managing multiple appointments with specialists, making sure the insurance plan covers a rare drug or treatment, and finding a doctor who has accessible scales and examining tables. At the Center for Consumer Engagement in Health Innovation, we spend a lot of time talking about how to improve care for people with complex health and social needs. On our list are things like improving care coordination, utilizing shared decision making, and addressing the social determinants of health. One thing that’s certainly not on our list: imposing unnecessary barriers to coverage that do nothing to improve health outcomes.

Unfortunately, unnecessary barriers to coverage might become more common for many people with complex health needs who receive their health coverage through Medicaid. The Centers for Medicare & Medicaid Services (CMS) recently announced that it will allow states to impose work requirements on Medicaid beneficiaries. Requirements that people on Medicaid work in order to maintain their health coverage are particularly harmful to people with disabilities or complex health needs. 

Many People with Disabilities Will be Subject to Work Requirements

Although the Trump administration has said that work requirements can’t apply to people who receive Medicaid because they qualify for disability benefits like SSI or SSDI, there are millions of people on Medicaid who have disabilities or complex health needs who are not on these programs because their income is not low enough or their conditions are not considered serious enough to meet the strict standards required to qualify for disability benefits.  Approximately three-fifths of all non-elderly adult Medicaid enrollees with a disability (meaning enrollees who report problems with hearing, vision, cognitive functioning, mobility, self-care or independent living) do not receive SSI or SSDI. These people could still be subject to work requirements. States may opt to exempt people who they define as “medically frail,” but these definitions are often narrow and would still leave many people with disabilities or complex health needs at risk for losing coverage if they aren’t able to comply with the work requirements.  

Additionally, barriers such as work requirements can create a chilling effect on Medicaid enrollment. Confusion, misinformation or overly burdensome paper work associated with new work requirements might discourage people from applying for the program in the first place or create the false impression that people who aren’t employed full time are no longer eligible, even if they would be exempt from the requirement.

Work Requirements Will Not Help People with Disabilities or Complex Health Needs Find Employment

Many people with disabilities or complex health needs either are, or desire to be, meaningfully employed and engaged in their communities.  Medicaid access is an important factor in making sure that can happen. For example, some state Medicaid programs provide job supports such as job training or referrals to employment resources for beneficiaries. And on an even more fundamental level, Medicaid helps ensure that people have access to the services they need to stay healthy and maintain the functions necessary for employment. Work requirements only create barriers to accessing these important services, undermining the entire purpose they purport to serve.

Work Requirements Will Have Negative Health Impacts on People with Disabilities

Medicaid helps millions of adults with disabilities get the care they need to stay healthy, including preventive services and acute care, medical equipment such as wheelchairs, and long-term care services. Evidence from other programs show that people lose coverage when work requirements are implemented and people with disabilities are disproportionately disenrolled for failing to meet work requirements. A loss or temporary interruption in coverage would be devastating for people with disabilities or complex health conditions who have ongoing, complicated care needs and can’t afford to miss necessary treatments. Additionally, studies demonstrate that losses in coverage lead to increases in costly services, such as emergency department use. Far from promoting improved health outcomes and community engagement, work requirements will only cause barriers to care and potentially increase health care costs. The impacts of this harmful policy will be especially acute for people with disabilities and complex health needs.